Update on 01-08-23:
Congratulations to Chris Hyomes for getting ERTA on BBC Radio 4 You and Yours Programme about it. Also our Bedford and Kempston MP has taken up the baton as well: https://mohammadyasin.org/rail-ticket-office-closure-consultation-response/ So a Bravo for all who are doing up proud and will this government listen? Consultation extended by a few weeks so far... we all remember the rail concessionary card attempt to eradicate them at Privatisation? It back-tracked! Costs have spiralled whilst most ordinary people are priced off public transport and government subsidies for more roads/road-based guzzling or battery jobs-at-any-cost, when reopening local railways would massively boost sustainable employment and supply chains. Yet Labour itself is not pro-green as much as it should be it seems. So all need continual lobbying and levelling up for equality for all in better public transport access, but affordability as well in the wider environmental interest please. Join our free newsy loop via requests to richard.erta@gmail.com
Advisory 30-07-23
"Ongoing to my previous emails, I'm just wondering if you can ask various organisations such as Transport for All, Inclusion London, or any other organisations that are planning to take legal action against the Mayor of London and Transport for London as they have breached the Equality Act 2010 and section 141 of the Greater London Authority Act 1999 for ignoring the overwhelming concerns and objections published by the equality impact assessment and the Mayor's statutory transport duties on withdrawing Day Travelcards?
I know the Mayors up north of England is taking legal action against the government on railway ticket office closures, but I'm hoping if any organisations is taking legal action against the Mayor and TFL on the unfairness of withdrawing Day Travelcards?
The next hope in saving the Day Travelcards is legal action, and it will certainly be damaging to the Mayor and TFL if they face court action. As we know, the Mayor is already facing legal action over the ULEZ expansion by a number of Tory run councils, and the expansion plan is likely to get delayed by the courts. I have no comment about the ULEZ as I don't drive.
I'd be grateful if you can reach out to them."
Please join and offer to help those organisations and MP's for example who are working together to take legal action if TfL/DFT/Treasury/Government do not back down!
Update at 24-07-23
ERTA receives the information from an anonymous researcher and merely passes it on in the wider public awareness interest. Personally, I think you are mistaken to split hairs between TOCs and TFL as overall these sub-groups are the DfT, Treasury and Government at large. They have the power and authority, they may delegate to reduce risk, liability and responsibility, but buck really does stop with government. We do make our views known as per the related closure of ticket offices, which will disenfranchise a swathe of non-digital people.You may find the information below of help as well.
I'm not sure, but TFL says that the daily caps on Oyster and PAYG will continue, they are a little cheaper than the Day Travelcard, but this is not the case as I will explain below.
But I'm aware TFL and DFT is expanding contactless PAYG to hundreds of stations in the South East of England in hopes it will counter-balance the withdrawal of the Day Travelcard.
I've found one document posted by someone on social media, the document is titled "New revenue sources - Transport for London - August 2021"
On the small print of every page, it says:
"This document is being provided in accordance with a condition of the TfL funding agreement dated 1 June 2021, which required TfL to present a review of potential new income sources to Government. The contents of this document do not represent TfL or Mayoral policy, or a decision on any of the options listed. The purpose of this document is to give a preliminary indication of the potential receipt associated with each theoretical option listed without consideration of their acceptability to the relevant decision maker(s). Any options that are to be developed will be subject to a detailed assessment and legal review. A full impact assessment and consultation may be required before any decisions about implementation can be made. The contents of the document are confidential and should not be disclosed to any unauthorised persons"
The table on page 23 of the document says:
Withdrawing from the Travelcard Agreement
Outcomes
Major MTS / economic outcome and impact
• Positive impact on journey time and ease of travel due to focus on contactless and PAYG.
• Increased cost for some commuters, subject to number of trips made over a year.
• Promotes demand for public transport alongside walking and cycling due to Seamless PAYG travel and simpler ticketing propositions
Equality impacts
Some impact on older customers due to digital exclusion
Finance
Costs and income
Income p.a. £55m including cost savings
Feasiblity
Key risk and issues
Level of complexity for implementation due to considerations around phasing out valid travelcards and technical aspect of ensuring the capping rules are consistent across Travelcards and other travel products
Earliest ‘go live’ date
Late 2022/23
On page 26, it says:
Withdrawing from the Travelcard Agreement
Travelcards are a range of tickets which are valid for use on National Rail services in London, as well as TfL services. Travelcard users are now a minority as customers gain many of the same benefits from other ticket types due to the introduction of Contactless and Oyster Pay As You Go. With the offer of daily and weekly capping, these products offer more flexibility to most customers. Moving customers to PAYG and retiring all magnetic tickets will simplify retailing, while reducing costs (by c.£20m p.a.) mainly due to a reduction in commission payments. Income would also increase by c.£35m p.a., due to a reduction in fraud associated with magnetic tickets and the end of special discounts for annual tickets.
The Travelcard Agreement allows TfL to withdraw with 13 months’ notice.
I've searched the 'What Do They Know' website, and I've noticed someone made multiple freedom of information requests to the Department for Transport, Department for Levelling Up, Housing & Communities, Greater London Authority and Transport for London questioning about the 'new revenue sources' document. So far, still waiting to see if they respond to these freedom of information requests.
The Mayor of London has certainly made the consideration to withdraw the Day Travelcard too early because contactless PAYG is not fully enabled at stations in the South East of England.
Besides, the Mayor and TFL should not be withdrawing the Day Travelcard at all as it will affect various groups of people including the disabled, older people, digitally excluded, foreign tourists (not all foreign contactless cards work) and railcard holders.
Here's the texts from the supporting documents of the equality impact assessment:
Appendix 5 – stakeholder responses
3. Stakeholder engagement The following is a summary of information provided to TfL by stakeholders and individuals on the potential impacts of the proposal. Information provided as to general impacts are set out first, followed by impacts relevant to those with Protected Characteristics.
General impacts
The cost of travel for those travelling into London from out of boundary will increase considerably, compared to current Day Travelcards added on to a National rail ticket and Group and Family Day Travelcard options.
Travel will become less convenient and will not be seamless, particularly for those travelling into London from out of boundary.
Customers outside London cannot buy Oyster cards at their station of origin, and some travellers do not wish to use their debit cards (for security and other issues). They will have to queue to get/renew/add money to an Oyster card. If the Travelcard is withdrawn, steps should be taken to ensure those who live anywhere outside London can purchase an Oyster card before outset of travel.
Oyster card cannot be topped up from numerous facilities that ought to accept it, including much of the TfL and National Rail networks.
The move will discourage out of boundary travel/visitors to London, and will be particularly problematic to occasional visitors who do not have Oyster.
It is easier to apply discounts, such as child fares and Railcards, to a travelcard.
The Oyster PAYG system is unreliable, and not as convenient as Day Travelcards.
There is increased risk of fraud when using a credit/debit card at the gates multiple times and the potential inconvenience of having to reclaim any charging errors.
The withdrawal of Group/Family Day Travelcards could result increase queuing for individual tickets. The withdrawal of Day Travelcards will discourage use of public/sustainable transport, and could result in increased car use with associated environmental implications. TfL should offer a range of ticketing options to encourage use of its network.
Overseas customers may be negatively impacted because not all foreign debits cards contactless functions work in the UK, or may be charged for this each time.
This proposal will affect both people who live in London and visitors alike, adding cost and complication to travel in and around London. Worsening the reputation of London as good place to visit, but very expensive.
The withdrawal of day Travelcards will have a detrimental impact on London’s economy through not spreading travel demand and increased costs reducing the appeal or capability for people/groups travelling into London.
The proposal is unlikely to generate much revenue because customer numbers travelling to London from outside are likely to decrease; given the increased cost of travel for families and groups with Family and Group Day Travelcards no longer being available. It is likely that the change will result in a loss of income for TfL as potential passengers abandon public transport. There would be no savings for TFL in maintenance costs as TFL will be to maintain the infrastructure to support weekly and monthly Travelcards. The loss to the London economy could be far larger than any savings or extra income that TFL are expecting from scrapping the Travelcard.
It is incompatible with the mayor’s transport strategy which seeks to ensure that 80% of all trips in London be made on foot, by cycle or using public transport by 2041.
Age
Adults who do not have a bank card or and Oyster will have to obtain and Oyster card or will be unable to obtain an off-peak fare on the rail network or be able to use a bus which is cashless. It will negatively affect those who do not possess contactless technology or an Oyster, who are often from underrepresented groups. Not everyone is willing or able to use Contactless or Oyster. The digitally excluded remain an important minority of users, including a key demographic of older overseas visitors.
Contactless or Oyster can be confusing or daunting to some, especially older people. It is easier to apply discounts, such as child fares and Senior Railcards, to a travelcard. Senior and disabled card holders (who do not have a Freedom Pass) will not be able to obtain discount on off-peak fares unless they obtain an Oyster card and register their railcard. The cost of travel for those travelling into London from out of boundary and for users of group or family Day Travelcards will increase considerably, compared to current Day Travelcards added on to a National rail ticket.
Customers outside London cannot buy Oyster cards at their station of origin, and many older travellers do not wish to use their debit cards (for security and other issues) People with children and teenagers purchase Day Travelcards which are much cheaper and more convenient.
Children who are not regular travellers and do not have an Oyster Zip card will have to obtain one or pay single peak fares, which could not be used on the bus as they are cashless. Obtaining an 11-16 Oyster Zip card or a Visitors Oyster is both complex, lengthy and difficult and they need to be ordered in advance. The cost of Oyster Zip card for a casual visitor or users is £14.00. This is both prohibitive and also can only be purchased in advance, on line and requires a photo. It can also take up to 10 days to deliver.
The alternative of a Child Visitors Oyster is complex. It has to be purchased in advance. It has to be registered at a Tube station. This does not take into consideration that the majority of South London is a considerable distance from the nearest tube station and would require purchasing a single ticket to the neatest tube station to register the Visitors Oyster.
Even where a child between the age of 11-16 has a bankcard the technology TfL uses will not be able to distinguish that it is a child and will charge the adult fare.
Withdrawal of the Family Travelcard will increase the cost of travel to London for families. On reaching London children will have the same problems if they do not have an Oyster Zip card. The cost may even be prohibitive for families and young children.
Unless the Children over the aged of 11 have an Oyster Zip card or a Visitors Oyster card. They will have to buy single tickets for the underground, but will not be able to use the bus.
Debit cards are not practical / cannot be used for more than one adult, and so cannot be used to pay for fare paying children. There is also the additional problem of tapping in and out after each journey especially with say a large family whereas the problem does not arise with paper Travelcards.
Customers taking advantage of any TOC offers for travel into London (e.g.: Southeast Trains “Kids for a Quid” where an adult can buy up to 4 child tickets for children who are accompanying them for £1.00 each), will have difficulties for onward travel if they do not have a bankcard or an Oyster Card. They will have to purchase single tickets on the underground, but will not be able to use the bus. Unless the Children over the aged of 11 have an Oyster Zip card or a Visitors Oyster card. They will have to buy single tickets for the underground, but will not be able to use the bus.
The withdrawal of Group Day Travelcards is likely to significantly impact school parties, because the alternative is using separate individual Oyster cards, or separate paper tickets.
Withdrawal of the One Day paper Travelcard will disadvantage many groups of travellers including: Families, children, group travellers, and others (see below - those on lower incomes and without access to smart technologies, those without bankcards.
Disabled People
Travelcards make it easier for disabled people to travel.
Some disabled people using Oyster and Contactless PAYG have been issued maximum fares for exceeding the maximum time allowed for journeys, because of needs for breaks and waiting for assistance with ramps. Maximum fares can only be corrected and refunded three times within a calendar month.
Some wheelchair users find it difficult and stressful trying to get close to ticket barriers to tap in and out; with Day Travelcards they show these and are let through.
Other disabled people are likely to have difficulties tapping in and out. Some stations only have tap out readers and no gated barriers, meaning it is very difficult to find the right place to tap out, with the potential to get charged the maximum fare. Often, these readers are not at a high level of contrast with the surrounding environment, meaning that they are hard to see, particularly for blind and visually impaired people.
Some people with learning disabilities use Day Travelcards to help them budget.
For some disabled people the PAYG system can be complicated to understand, including loading any Disabled Persons Railcard, and tapping in and out. It is much easier to have a paper-based ticket which does not require tapping in and out.
Those with mobility or language barriers are likely to find Contactless / Oyster more difficult. Disabled card holders (who do not have a Freedom Pass) will not be able to obtain discount on offpeak fares unless they obtain an Oyster card and register their railcard, which could be difficult for some.
Companions of Disabled Persons Railcards, who currently benefit from a railcard discount, would lose this which could be a barrier to travel for the disabled person.
Low income / other
It will negatively impact those who do not possess contactless technology or an Oyster, who are often from underrepresented groups. Not everyone is willing or able to use Contactless or Oyster. The digitally excluded remain an important minority of users. The cost of purchasing Oyster will be an issue for some.
Will be disadvantaging the most vulnerable and poor in society.
Withdrawal of the One Day paper Travelcard will disadvantage many groups of travellers including: including those on lower incomes and those without access to smart technologies, those without bankcards. Work done by London Travelwatch shows that up to 20% of people do not have access to modern technology.
Suggested mitigations
Below is a summary of mitigations suggested in responses.
Contactless should accommodate “Railcards" or discounts of any type.
It is important that the infrastructure, such as “touch-points” for reading "Contactless" devices are in place and fully functioning prior to any future introduction.
Full impartial advice must be given to passengers, advising them of the new arrangements and the best and economic way to pay for their journeys.
Also to mention from Caroline Pidgeon MBE AM:
Moreover, anyone who is entitled to claim back their travel (e.g. for study or work purposes) usually needs a receipt or ticket as proof. It's much harder to evidence such journeys if they are done using contactless payments. If One Day Travelcards are going to be phased out then TfL needs to look at how evidence of travel can be provided easily.
A further concern is that people who have their wallets stolen could temporarily be dependent on One Day Travelcards to continue to travel whilst they await their replacement cards.
As crime is increasing and some people lose their wallets including contactless and Oyster cards to theft, then they won't be able to travel (especially on London's buses as they have been cash-free for many years) because the new Oyster card costs £7 without refunds and they had to wait for replacement cards to arrive in the post.
Therefore, the Day Travelcard must be retained as an alternative way to travel in London and to reduce barriers for protected groups defined by the equality act.
I know the information is huge and detailed, please spread the word!
VERY BAD NEWS: THE MAYOR GIVES A GREEN LIGHT TO WITHDRAW DAY TRAVELCARDS DESPITE STRONG OPPOSITION!!!!
Dear All,
VERY BAD NEWS: THE MAYOR GIVES A GREEN LIGHT TO WITHDRAW DAY TRAVELCARDS DESPITE STRONG OPPOSITION!!!!
Despite the strong opposition made against TFL's proposal to withdraw the Day Travelcards, unfortunately the Mayor has given a green light to start the withdrawal process.
Here's the Mayoral Decision on proceeding with the withdrawal.
https://www.london.gov.uk/md3142-withdrawal-day-travelcards-tfl-network
You should check out the Equality Impact Assessment and the supporting documents showing strong opposition to the withdrawal.
https://www.london.gov.uk/media/101984/download
https://www.london.gov.uk/media/101985/download
On the supporting documents, I've seen your comment got mentioned by the Transport for All, and another comment mentions about the potential breach of the Mayor's statutory transport duty, as outlined in section 141 of the Greater London Authority Act 1999.
https://www.legislation.gov.uk/ukpga/1999/29/section/141
TFL has updated their engagement page on their proposal.
The text says:
"The Mayor has now considered our proposal, and after careful consideration, including information you provided in response to the engagement exercise, an Equality Impact Assessment (EqIA) and requirements under our funding settlement with government, the Mayor has reluctantly instructed us to give the required minimum six months’ notice to withdraw from the relevant provisions of the Travelcard agreement.
While this six-month process is now underway, it is important that we are clear this remains reversible and does not therefore mean that Day Travelcards will be withdrawn. We and the Mayor remain open to discussing all options with both the Department for Transport, the Rail Delivery Group and the train operating companies, but in a way which would allow us to continue to meet the requirements of the government funding agreement.
We would like to reassure you that while these discussions take place Day Travelcards will remain available. The existing daily pay as you go caps on contactless or Oyster, which are used by the overwhelming majority of those travelling, will not be affected by this.
We are engaging with key stakeholders to develop our impact assessment on the potential change."
https://haveyoursay.tfl.gov.uk/travelcards
If they fully proceed with the proposal to withdraw the Day Travelcards, organisations such as Transport for All should take legal action against TFL, the Mayor and the government on the grounds for breaking the Equality Act 2010 and the Mayor's statutory transport duty, as outlined in section 141 of the GLA Act 1999.
I'm afraid taking legal action is now the only option.
The Secretary of State also have the power outlined in section 144 of the GLA Act 1999 to veto TFL and the Mayor's proposal as "the inconsistency is detrimental to any area outside Greater London", especially for people living outside of Greater London which uses the outboundary Day Travelcards. The government should stop playing politics by saying "this is a devolved matter to TFL/Mayor" as they have the legal power to stop the process! I've noticed that they said the same in regards to the ULEZ expansion to Greater London.
https://www.legislation.gov.uk/ukpga/1999/29/section/143
On the side note, yes I'm fully aware of the government's proposal to close a huge amount of ticket offices at railway stations and there's a legal challenge on this. I'm also in opposition to the proposal for various reasons as well.
These proposals prompt a complete waste of money, and it will cost more taxpayers and farepayers once TFL, Mayor and the government to defend their legal challenge. All we simply want to do is travel using public transport without any issues, that is why I ignore the news because of the constant politics which causes harm to my mental health.
There's a saying: "If it's not broken, then don't fix it!"
ERTA would recommend emails to MP’s and Transport for London (TFL) in any case and reinventing the wheel seems in vogue again! i.e. we close something, then reopen it later thanks to campaigning, common sense prevailing and because tried and tested means speak for themselves eventually... maybe like the ideal privatisation would deliver better public services for less... jury out at very least! Local Railways, now ticket offices and tickets, schools, hospital beds, bank branches, railway stations, mental health outlets, trams... the list goes on.
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