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A NEW APPROACH TO RAIL PASSENGER SERVICES
IN LONDON AND THE SOUTH EAST: CONSULTATION
RESPONSE BY
Introduction
1.1
welcomes the opportunity to respond to the
consultation on “A new approach to rail passenger services in London
and the South East”.
1.2 We note the proposal includes the transfer of responsibility from the
DfT to TfL for inner suburban rail services that operate mostly or
wholly within Greater London, as current franchises fall due for
renewal. We also note that the DfT will continue to be responsible for
outer suburban services.
1.3
has a significant interest in this proposal
due to its clear association with the Thameslink network.
Detailed Comments
1.4 We note that the key recommendation is to set up a partnership
between TfL and DfT that will allow a forum to give LEPs and local
authorities a say in determination of service patterns and
infrastructure requirements. Whilst the document is clear that this
applies to local authorities within the immediate environs of London it
is not clear how this mechanism would reach out to local authorities
beyond the core area, such as Bedford who may be affected by
decisions made in the partnership area.
1.5 We commend the approach that changes would only occur as
franchise become susceptible to renewal. We note that this is on the
proviso that the current franchising timetable is closely adhered to.
Changing of the strategic specification of franchises through further
direct awards or unplanned short term extensions will create a degree
of uncertainty that will hinder land use planning and make economic
development problematic in areas such as Bedford due to the
unknown and unplanned effect on the south east rail network.
1.6 We address the specific consultation questions below.
Question 1 Do you agree with the principle of a partnership to better
integrate the specification of rail passenger services across London
and the South East?
A partnership approach is eminently suitable for this task. The key
issue for Bedford is that safeguards are offered to local authorities on
the fringes of the partnership area that are affected by proposed
service or infrastructure changes within the partnership area.
Similarly,
is part of the emerging England’s
Economic Heartland Strategic Alliance, which has established a
Strategic Transport Forum with the specific intention of providing the
focus for a single strategic conversation with Government. The
strategic interests of partners outside London must be reflected in any
proposed partnership arrangement and we would suggest that the
proposed partnerships should not be limited to DfT and TfL.
Question 2 Do you agree with the principles that the partnership will
work to? Are there any specific issues that have not been captured?
The key issue for Bedford is that proposals to increase frequencies in
the partnership area are not detrimental to the provision of services to
Bedford. We see no mechanism in the current proposal by which this
would be protected. This lack of certainty could lead to adverse
economic consequences if labour market access for Bedford and
businesses which rely on Bedford as a source of labour is not
maintained. We provide further comment on this point in respect of
questions 5.
We are supportive of the proposal to improve interchanges, provide
greater reliability and increase levels of customer care.
Question 3 Do you agree with the proposed governance
arrangements?
We have no specific comment on the governance arrangements and
timing beyond those made in our previous observations and would
reiterate that accountability for coming to a recommendation to the
Secretary of State and Mayor of London should not rest solely with
DfT and TfL.
Question 4 What form do you propose the input from local authorities
and LEPs could take?
We are disappointed that the Prospectus makes no initial view known
by the DfT and TfL as to possible governance arrangements. We
have already referred to the need for the governance arrangements to
take cognisance of the input from relevant public bodies outside the
immediate area involved in the proposed partnership.
is party to both the East West Rail Consortium and
the new sub regional transport body (England’s Economic Heartland
Strategic Alliance) which provide a voice on major transport issues in
the northern home-counties. These bodies should be party to the
partnership’s working arrangements.
Question 5 Do you agree with the safeguards for transfer of inner
suburban services to TfL, as set out here?
The safeguards proposed whilst stating that there will be no
reductions in service frequency, journey times or station stopping
patterns, are limited in the sense that that they not provide protection
for future necessary changes or enhancements. The safeguards
should protect the relevant factors at the time of transfer and not at
the current time. The approach of the Secretary of State to addressing
competing proposals within and outside the partnership area needs to
be made explicit within the partnership’s terms of reference to ensure
decision making remains transparent. We would also expect that the
appropriate level of funding for rail investment is retained irrespective
of the governance arrangements in place.
Question 6 Are there other outcomes you might expect to see
achieved?
We note that the Prospectus sets out possible short, medium and
long-term objectives including likely schemes and interventions.
Whilst this is welcomed we note that some of the proposals such as
the possible changes relating to Thameslink and Crossrail-2 could
have implications (both positive and negative) for rail services across
a far wider area north of the Thames than Hertfordshire.
We would expect this wider effect to be discussed as a specific
outcome in terms of economic opportunity.
Whilst we are supportive of the intentions behind the principles
underpinning the proposals, the consultation document should take
into account existing partnerships as well as the emergence of
strategic sub-national partnerships.
Contact
1.7 For further information please contact