Monday, 15 May 2017

Response to the South Eastern Rail Franchise Public Consultation

Many of you will be aware of this consultation, whose closing date is Tuesday, 23rd May.   Although the forthcoming general election has nullified the on-line petition, this date still stands so we must presume the Department of Transport will pick the subject up once the election is over.

We have sent our response on-line because we believe government departments are more likely to take note comments submitted in this way.   Anyone who would like to respond as an individual is more than welcome to make use of out text if they so choose.    To do so on-line, go to and click on the link 'Respond online'.   
South Eastern Rail Franchise
Consultation Co-ordinator
Zone 4/13
Department of Transport
Great Minister House
33 Horseferry Road
London  SW1P 4DR

15 May 2017

Dear Sir,


Our Association represents the 1,298 homes that comprise the Progress Estate Conservation Area.   We estimate these are occupied by some 2,500 – 3,000 adults, many of whom will regularly use the South Eastern rail service from Eltham to London for either work or leisure purposes.

Having studied the consultation document we believe the issues it raises have to be viewed from the perspective of two groups of people:

1. The disabled and those of senior years (referred to hereafter as ‘the Less Able’ which phrase includes, where the context so admits, their Carers).

2. The Able-Bodied.
The reasons for this distinction will, we trust, become clear as you read our answers to the questions the Consultation poses.

1. Do our priorities correctly reflect your views?
We would expect the major concern of the Able-Bodied to centre on the total journey time from their point of departure to their destination together with the frequency of the service.   Changes en route ought to be a lesser consideration.   However, for the Less Able the need to change trains presents challenges, especially at stations not served by modern infrastructure.

2. Do you agree that more space is needed for passengers at the busiest times of the day?

We are very concerned about the proposal to introduce of Metro trains.   These simply do not work for those amongst the Less Able who cannot stand comfortably for the duration of their journeys.   We would ask you to consider adding conventional carriages for the requisite proportion of a train’s length (which survey data may lead you to conclude varies from one line to another) and, during peak times, restrict their use to those with disabled badges and Freedom Passes.

3. What comments, if any, do you have on options for providing more space through (a) Longer trains; and (b) Metro style carriages with large entrances and more standing room and handholds?

We have expressed our views on Metro style carriages in (2).   We welcome your suggestion that space be added for wheelchairs and pushchairs ‘on shorter journeys’.   This does not, however, address the problems of those members of the Less Able who, whilst not being reliant on wheelchairs, nevertheless find it very uncomfortable to stand for the duration of their journeys.

4. Would you support removing First Class seating on the busiest routes to provide more space?


5. What comments, if any, do you have on our plans to improve customer service and the overall passenger experience?


6. Do you have any other ideas or priorities for improving customer service?

Beyond the important issues relating to the Less Able we are addressing in answer to your questions, our only comment would be that providing wi-fi in these days when iPhones are the dominant form of mobile communication is not necessary.   On a busy Metro train, when a higher proportion of the passengers are standing, how many will be attempting to use laptops?

7. What changes to the fares structure would be of benefit to you?

8. What else could be done to improve the way tickets are sold and provided?

No comments.

9. What further comments, if any, do you have on our plans to improve access and facilities at stations?

This question raises what for us is probably the most important issue in this consultation.   There is a suggestion in paragraph 4.6 (and we appreciate that this may be all that it is) that the complexity caused at key points such as Lewisham requiring trains to cross other tracks to continue to their destination can lead to queuing and delays.   The remainder of our comments for this question are limited to services running through Lewisham because we do not have knowledge of other cross-over points on the service.

At present, people may board trains east of Lewisham that offer direct services to the termini of Victoria, Charing Cross and Cannon Street.   Subject to final timetabling when London Bridge is fully re-opened, the trains for the latter two also provide direct journeys to the important intermediate stations of New Cross (an access point for the Overground), London Bridge itself and London Waterloo (East).  Trains to Victoria provide direct access to Denmark Hill, home to the Kings College and the Maudsley Hospitals.   Kings College is a nationally and internationally recognised teaching hospital for liver disease, transplantation, neurosciences, hæmato-oncology and fœtal medicine, these services being provided to people throughout the south-east.   The South London and Maudslay NHS Foundation Trust provides the widest range of public-sector mental health services in the UK.

There will be significant difficulties if direct services only run to one of these three termini, caused by people having to change for trains to the other two at Lewisham:

a) For the Less Able, there will be two problems:
i. Access from one platform to another is only by staircase; there are no lifts or escalators.
ii. The curvature of platform 2, serving the downline, is such that there is a 12-18 inch gap between carriages’ running boards and the platform as well as a drop between the two.
b) Lewisham is a busy station at peak times.   Significantly-increased numbers of passengers changing trains might lead to worrying levels of congestion.
We are of the opinion that unless and until Lewisham is fully modernised, greatly increased numbers of passengers changing trains there will cause frustration for all and effectively force the Less Able to find ways of journeying to destinations other than the remaining destination by means other than rail.   We trust you will agree it would be quite wrong to force this choice upon them.

Finally, we would point out the relevant statutory duties the Equality Act, 2010 places upon, amongst others, train operators:

s.20 – Duty to make adjustments [for disabled persons]

(4) where a physical feature puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, to take such steps as it is reasonable to have to take (a) to avoid the disadvantage, or (b) to adopt a reasonable alternative method of providing the service or exercising the function. [Schedule 2, 2(3)]

(9) In relation to [this requirement], a reference in this section or an applicable Schedule to avoiding a substantial disadvantage includes a reference to—

(a) removing the physical feature in question,

(b) altering it, or

(c) providing a reasonable means of avoiding it.

(10) A reference in this section … to a physical feature is a reference to -

(a) a feature arising from the design or construction of a building,

(b) a feature of an approach to, exit from or access to a building,

(d) any other physical element or quality.

Schedule 2 - Services and public functions: reasonable adjustments

(5) Being placed at a substantial disadvantage in relation to the exercise of a function means—

(a) if a benefit is or may be conferred in the exercise of the function, being placed at a substantial disadvantage in relation to the conferment of the benefit, or

(b) if a person is or may be subjected to a detriment in the exercise of the function, suffering an unreasonably adverse experience when being subjected to the detriment.

10.    What more could be done to improve access and provide facilities for those with disabilities and additional needs?

No suggestions; as you will have gathered from our response to question (9), our current concern is that, for them, the service becomes significantly worse.

11 – 16

No comments.

17.       How far do you support, or oppose, options to reduce the choice of central London destinations served from individual stations with the aim of providing a more regular, evenly spaced timetable, and a more reliable service?

Absent a considerable modernisation of Lewisham station we do not support these options.   In our opinion, the suggestion in the wording of this question – that its implementation would carry benefits that are otherwise unachievable - is disingenuous.

18 - 20

No comments.

Yours faithfully,

On behalf of the Committee

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