Dominic Lund-Conlon / RDG tried to stop all booked assistance during Storm Eunice, and lied to the ORR.

All train and station operating companies are required as part of their Accessible Travel Policies (i.e. as part of their operating license) to provide booked assistance to disabled travellers, and to accept bookings for said assistance to be provided.

This has been the case for at least 25 years to my recollection, probably longer. In all that time, there has never been any day on which any operator simply cancelled and refused to provide booked assistance, or any day for which any operator refused to carry out any bookings (except for e.g. Christmas Day, when there are no train services for any passengers, disabled or otherwise.)

That is, until 18th February 2022. On 17th February, Govia Thameslink Railways (GTR) decided to cancel all assistance bookings made for the 18th, and to refuse all new assistance bookings for services run that day, due to the “Do Not Travel” advisory (Storm Eunice).

(Note that word “advisory”. The industry was still running trains, selling tickets for those trains, and indeed people travelled on those trains, despite being advised not to travel. Despite this, GTR cancelled and refused all bookings for assistance that disabled people need in order to travel.)

My assistance booking request for a journey for that day was cancelled by GTR.

How was this decision made to cancel and refuse all bookings, one wonders?

Faz Hakim, GTR’s Head of Public Affairs, (whilst tweet-gaslighting a disabled passenger) claimed the “advice and guidance on providing assistance was agreed with other Train companies, the Rail Delivery Group and the Office of Rail and Road“. This is demonstrably untrue.

In reality, the decision wasn’t made at any meeting, with the involvement of any train or station operating companies, nor with the approval of the Office of Rail and Road (ORR). The decision was made solely by Rail Delivery Group, through its accessibility and inclusion manager Dominic Lund-Conlon (who tweets as @DaddyDoink.)

The lack of transparency and accountability in this decision is breathtakingly revealed in Northern’s Freedom of Information release. The decision was communicated in an email chain on a rail industry “accessibility” email group, including train operator accessibility leads and Rail Delivery Group. You can read the whole email chain. or here are the highlights.

On Thursday 17th lunctime, our Dom instructed operators to be prepared to contact customers to rearrange journeys.

GTR’s Customer Relations Operations Manager commendably asked legitimate and measured questions:

Given the strength of the ‘Do not travel’ message, we would appreciate industry clarity whether we should/could cancel booked travel altogether over this period as to take a booking for a journey that we know is highly likely to be disrupted may set an unrealistic expectation.
Conversely, refusing a booking, as we know goes against everything we would normally do, so this is uncharted territory.
Appreciate urgent guidance on this so the advice we provide to our booked customers is consistent with industry; ie whether we should refuse a booking if there is a general ‘Do not travel’ message in place?

To which our Dom responded at 12:37, saying simply,

If “Do Not Travel” is in place, then you can’t offer journeys that you are actively telling all customers not to make.
I will email the ORR to set out the situation if the group would like me to?

GTR required confirmation:

Getting ORR confirmation asap would be much appreciated.

as did LNER:

Yes please
– obviously we kind of need a response in hours so hopefully they’ll understand the urgency.

However, instead of asking the ORR if it was OK to cancel and refuse bookings, Dominic simply informed them what he incorrectly claimed operators were already doing. Dominic emailed the following lie to the ORR:

I would like to update you on the current work underway in relation to passenger assist bookings for Friday 18 February and the “Do Not Travel” notice issued today.
At present, all train operators are undertaking proactive contact with customers who are booked to travel on Friday to rearrange their planned journeys. Alongside this, members will be not accepting any new booking requests from customers for Friday

The ORR thanked our Dom for his update.

That was the extent of the decision-making process for the (ostensible) decision to cancel and refuse the entire nation’s assistance bookings for a 24-hour period. It simply consisted of Rail Delivery Group (likely Dominic alone!) making the decision, Dominic himself instructing operators to cancel and refuse bookings, and Dominic lying to the ORR that all operators were already doing so.

Happily, most operators did not cancel or refuse bookings for assistance, despite Dom instructing them to do so and despite his claim to the ORR that all operators were.

• Network Rail said: “all of our managed stations who deliver passenger assistance continued to deliver both booked and unbooked passenger assistance during Storm Eunice. We did not cancel or refuse any assistance bookings or requests and all normal processes were followed.“
• Northern: “On 17th February 2022 Northern cancelled some services in anticipation of the disruption Storm Eunice would cause. Northern then attempted to make contact with customers who had booked passenger assistance on the services that were cancelled and helped them make alterative arrangements. Northern did not cancel the bookings of services scheduled to run and provided alternative transportation when there was further disruption on the day.
  Northern did not refuse to take new bookings. Northern advised customers of the Do Not Travel advisory, but if a service was scheduled to run Northern accepted the booking for passenger assistance if that was what the customer wanted to do.“
• SouthEastern: got staff to contact customers with booked assistance to warn of likely disruption and offer to rearrange their journey. “Of the people we spoke to, three confirmed they would still need to travel. We maintained these bookings but on the advice not to travel because we were expecting disruption to services and some lines of route may have to close. As per our message to all customers, this included that alternative transport could not be provided should a line have to close.” – though “we didn’t take new pre-bookings for Assisted Travel journeys on 18 February.“
• LNER: “We followed a BAU (Business As Usual) process of contacting all customers with booked assistance as a welfare check and to offer to re-arrange. Passenger assistance bookings were cancelled where a customer informed us that they were no longer travelling and we made amendments where necessary to coordinate with services that were able to run. We would have accepted any further assistance bookings”. On Lund-Conlon’s email to the ORR saying that TOCs were cancelling and refusing assistance bookings: “Please note, LNER did not endorse this response, and neither is it the course of action that LNER took“.
• Scotrail: “ScotRail did not follow the advice given by RDG and continued operating services as normal. The decision was taken based on the information available that suggested that Storm Eunice was unlikely to affect much of Scotland. Passenger Assistance was provided as normal for ScotRail passenger.”
• GWR informed me that they did not cancel or refuse any assistance bookings. They contacted customers with booked assistance to advise of the potential issues, but maintained the booking where this was the customer’s preference.
• Transport for Wales: cancelled all their trains during Storm Eunice, so consequently cancelled relevant assistance (as nobody could travel on their services, disabled or not.)

Rail Delivery Group‘s legal name is the “Association of Train Operating Companies“. They are not a public body, so they aren’t subject to the ORR (the regulator), to the Public Sector Equality Duty or to transparency such as the Freedom of Information Act. Their role is nebulous and poorly-defined; as the Williams Rail Review noted. But it is clear that they are NOT there to make unilateral decisions and inflict them on their own members (the train operating companies and Network Rail.)

As for Dominic Lund-Conlon: that he (thinks he) has the power to unilaterally decide to cancel and refuse all assistance bookings across the nation for 24 hours is astounding, and totally outside his somewhat lowly role. He does NOT have the power to instruct RDG’s members to do anything, nor the right to lie to the ORR about what RDG’s members are actually doing. (Who does he think he is; the God of rail access?)

It is widely thought that RDG, and particularly Dominic Lund-Conlon, are active impediments to access for disabled people to rail transport. Neither represent disabled passengers, or even their operating company members; and it is time that both went.

And my train? It ran, reasonably to time and with no problems. Without me on it, of course.

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Update Sunday 20th March 2022:

I have written to the Transport Select Committee, and to Wendy Morton (Rail Minister and Disability Champion) about this.

We can’t allow it to go unchallenged. Or repeated.

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Update Monday 21 March 2022

I have updated this article with responses from LNER and GWR.

Update Friday 22nd April 2022

I have updated this article with responses from Scotrail and TfW.