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.
Hello @railandroad.Glad we could confirm last night that the Do Not Travel advice and guidance on providing assistance was agreed with other Train companies, the @RailDeliveryGrp and @railandroad in advance. The advice to DNT was posted from 12.36 pm yesterday onwards. https://t.co/bLWfcZx2Jz
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.
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 heincorrectly claimedoperators 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.
Disabled people aren’t able to book train wheelchair spaces directly; we have to get A Rail Employee Human to do it. Doing so is ridiculously difficult.
Non-disabled people can book their seats on trains considerably more easily. But wheelchair users have to book the space as part of an Assistance Booking, for ramp provision and so on; and that ISN’T easy.
Traditionally, disabled people have had to make such bookings either by phoning up (which isn’t great for people with e.g. hearing impairment) OR by filling in a web form and waiting (which isn’t great because it isn’t interactive i.e. one has to wait and see if the wheelchair space has been booked; also because requests made via these forms routinely go AWOL.)
TransReport app
So enter TransReport. This small startup set up a partnership with Rail Delivery Group (RDG) and started developing an app that was supposed to Sort All Our Assistance Problems Out In One Fell Swoop. The app was to include revolutionary features, as advertised in this Sociable post:
“With the push of a button, rail staff can get to you quickly and easily – just wait for assistance to come to you,” says Founder Jay Shen
The staff member can even message the passenger and vice versa, so the staff member has a name too.
Since the staff and passenger can message each other, time can be addressed when schedules change or a mistake is made and Plan B is needed.
Through GPS tracking down to the metre, staff and passengers can be located easily.
Coming to all UK rail and train stations by June 2018.
June 2018 came and went with no sign of the app. So did June 2019, and then June 2020.
In Autumn 2020, TransReport took over the back-end database of assistance bookings. This database contains the approximately 1.25 million (pre-pandemic) assistance bookings made on the UK rail network each year. It has a user interface that allows staff at train operating companies’ call centres to check station accessibility, book wheelchair spaces and seats etc. and make assistance bookings. This information then (theoretically) gets transmitted to rail staff on trains and stations to provide the booked assistance.
This much-delayed app doesn’t have many of the promised revolutionary features.
No facility to allow staff and passengers to contact each other
No facility to know assistance staff names or what they look like
No facility for communicating changes when disruption or mistakes occur
No GPS tracking of the passenger.
There’s also no facility for booking a ticket; a fairly fundamental failure, in my opinion.
It doesn’t allow interactive booking of the wheelchair space; in fact, it makes no mention of booking wheelchair spaces at all.
Its sole benefit seems to be that it is (supposedly) a one-stop place to book passenger assistance, without having to work out whom to contact, with a comparatively accessible interface (thanks to the input of some excellent disabled rights activists) and with the passenger’s assistance needs and biographical details pre-filled in without having to redo them for each booking. This is a benefit, but nothing like that promised all those years ago, and sadly those benefits are offset by some significant problems.
Wheelchair space booking functionality broken
TransReport and RDG have really dropped the ball on this one, and stuffed wheelchair users up royally. What’s more, they won’t admit this fault and haven’t sorted it since they have been aware…
Since TransReport took over the database and backend last Autumn, I have experienced repeated and significant problems booking wheelchair spaces. Time and again I have attempted to book such spaces on LNER, particularly in 1st Class, only to be faced by “computer says no“. Over the phone (via Text Relay), web chat or email, LNER or Northern say: “sorry, the computer said that the wheelchair space was available but on attempting to book it, in actual fact, it seems the space has already been booked by somebody.“
After the first few times I was told this, I began to smell a rat. Were both First Class wheelchair spaces on each of four consecutive trains between York and Newcastle really booked up, three months in advance, during a pandemic?! Following much pressure and investigation, Northern and LNER eventually found out that the wheelchair spaces were NOT reserved. Wheelchair spaces simply weren’t reservable, because of TransReport’s software glitch. On actually travelling, I confirmed that the spaces had NOT been reserved by others and were indeed available to me
Each time that I attempt to book a wheelchair space, I experience the same problem. Multiple months after the first time it happened, it is still an issue. Eventually, LNER and Northern conducted investigations.
TransReport’s user interface was and is illegitimately refusing wheelchair space bookings, whilst other, older systems still allow them. So TransReport’s systems will tell train operating company employees that the wheelchair space isn’t available, and refuse to book it – then the older “Journey Planner” and “Portal” systems still allow rail employees to book the same space on the same train. Yet rail staff are instructed they must use the new TransReport system; and anyway many don’t have access to the older systems, or even know that this glitch exists.
To me, this is a pretty big failure. A system specifically designed to facilitate disabled people’s travel, in mandatory use across the country (inflicted on disabled people and on train operating companies whether we want it or not), has some fundamental bug preventing the booking of train wheelchair spaces – whereas the older systems still allow such.
I think what’s worse is that nobody at TransReport or RDG noticed this bug. Not during alpha or beta testing, in user and staff trials, and not in six months of operation. Their system was merrily refusing wheelchair users access to unoccupied wheelchair spaces for several months – and nobody noticed.
Only when LNER and Northern investigated the failure (at my prompting) was the issue brought to light. In the first week of June, RDG was shown that the system wouldn’t allow wheelchair space bookings whereas the older systems would. Yet:
TransReport and RDG refused to acknowledge the bug
the bug is still present three weeks later and is still preventing wheelchair space bookings
I’ll leave you to draw your own conclusions as to what this says about the competence of the two organisations and the priority they place on wheelchair users’ right to travel.
Other bugs and problems
The app doesn’t make clear anyway that it can be used to request a wheelchair space booking. The options listed – “Use of ramp, Room for Assistance Dog, Seat Transfer, Use of Station Buggy / Wheelchair, Help Pushing Wheelchair or Help with Luggage” – don’t include “Book Wheelchair Space“. There’s no mention in the app at all about booking the space, nor does their website say how to request one, despite my multiple suggestions to TransReport that they include such.
They’ve subsequently had to tweet to inform people:
Also, if your profile doesn't show you are a wheelchair user, you can say that you will be using a wheelchair within your request using the “Other Info” box when requesting your assistance. We hope that makes things clearer 😃
— Passenger Assistance (@PassAssistance) May 25, 2021
Other problems include:
if Train Operating Companies don’t mark a disabled person’s journey as “Completed” (which they never do) then the journey hangs around forever in the “Current Journeys” bit of the app.
the app and backend quite happily allows nonsensical bookings. For example, they allow booking assistance on and off the Underground (which can’t actually be booked), booking train ramps to be provided to board rail replacement coaches, or wheelchair spaces and ramps to be booked for stations that are only accessible by several flights of stairs
the back-end generates a multitude of confusing “unconfirmed,” “confirmed” and “altered” email confirmations to passengers
the app makes no warning when passengers make booking requests at impossible short notice, e.g. for a train in 5 minutes – which can never be actioned because:
a rail employee has to confirm each assistance and/or wheelchair space booking request. This often doesn’t happen. When it does, it also means that all the old problems with booking failures are still very much in evidence.
So the app and its backend isn’t the massive step forward we were all promised. It is a much-delayed, massive disappointment, with limited new functionality and with new bugs that prevent many disabled people from travelling.
South Western Railway cluster****
Next month I intend on seeing friends in Farnham. So today I attempted to book the journey back home via the app. I made the booking request at 16:27, and included the following seemingly helpful comments:
Wheelchair space. 1st Class where available.
NB: first class wheelchair space may not be available between Leeds and Harrogate either direction – short platform at Harrogate. If so, please book the standard class wheelchair space Leeds to/from Harrogate and the first class wheelchair space Harrogate to/from King’s Cross, with transfer between at Leeds.
Transreport has difficulties with booking wheelchair spaces, you may need to use Journey Planner / Portal.
I can manage steep ramps at Farnham.
My booking request was reviewed by somebody at South Western Rail, who confirmed my booking at 17:25. This generated a booking confirmation email to me. Said confirmation made clear that no wheelchair space booking had actually been made, despite my request.
My note above was copied verbatim into the booking multiple times. The agent had also booked me assistance onto/off London Underground, with train ramps and with the same note requesting wheelchair space booking…
The booking was clearly full of errors and not valid. So I sighed, girded my loins and phoned up SWR Assisted Travel via TextRelay (for deaf people.)
The call lasted over an hour, and I still don’t have a usable booking.
Here’s the transcript of the call. It’s long, infuriating but sort of cruelly entertaining. (I’ve removed my date of intended travel and a couple of pieces of identifying info.)
SWR Call Transcript
Relay UK. Ring Ring.
Relay UK Answered, please wait for connection.
Sorry for any delay. Connecting you as soon as we can.
Sorry for any delay. Connecting you as soon as we can.
Connected to Relay UK, pls wait…
Ringing…
Recorded Message
Thank you for calling SW Railway assisted travel service…
Note from relay assistant: Too fast.
Good evening. You are through to Linda. How may I help you?
Good evening. I booked assistance this evening by the Passenger Assist app, but the confirmation that has come through doesn’t show the wheelchair spaces as booked as requested. Please could you check and book the wheelchair spaces if needed? PA-XXXXXXXX Thank you.
And the name it has been booked under, please?
Doug Paulley.
And the postcode, please?
XXXX XXX.
And what date are you due to travel?
XXXday XX July.
…and what station are you travelling from and to?
I am travelling from Farnham to Harrogate. Have you found my booking?
Not yet no…
Booking reference PA-XXXXXXXX.
Yep, that’s exactly how you gave it last time… Unfortunately, I can’t find your booking. I am looking again, still searching. Can’t find nothing at all.
OK. I have the booking confirmation in front of me and it is confirmed on the passenger Assist app.
Yeah, I have just found the booking… One moment… OK, so it does say in the assistance ‘wheelchair space. First-class where available’ and then ‘first class may not always be available’.
I know. I typed that. That is my request to the assistance booking people. So, did they book the wheelchair space? Because I can’t see any indication on the booking confirmation that they have. If so, which coaches please?
Please hold the line while I get my team leader. One moment, please.
Holding…
Holding…
Holding…
Hello, sorry about that. So, the actual booking hasn’t actually been booked. It is ready to be booked but the actual assistance hasn’t been booked yet. It is on the system waiting. An agent hasn’t actually booked it yet.
They have booked it. It has gone from Unconfirmed to Confirmed after an SWR agent manually checked it and confirmed it. So, it has been processed.
Sorry, you’ll have to hold again. Thank you.
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…. Hello. Sorry to have kept you waiting so long. OK… So, we can’t book a wheelchair space on the first leg of the journey but the staff will try to get you a space, and there’s not usually a problem… They will do that… That’s Farnham to Waterloo… But then from London King’s Cross to Harrogate, you will be in Coach A 01 and that’s a standard class wheelchair space.
I requested the first-class wheelchair space. Please book it.
Unfortunately, there isn’t availability to book a first-class wheelchair space, so it is impossible for me to book it when it isn’t available.
It is available to book between Kings Cross and Leeds, as I made clear in my booking request. Please book the first-class wheelchair space between Kings Cross and Leeds, then transfer me to the standard class wheelchair space between Leeds and Harrogate, as originally requested.
Also, why did you claim that the booking hadn’t been confirmed, when it had? Why did SWR not tell me they had booked a wheelchair space? Why was my booking amended at 2200, was it someone on your end adding the wheelchair space because SWR originally hadn’t?
I was trying to find the booking so obviously had to make an amendment. If you wish to make a complaint you may do so by emailing customerrelations@swrailway.com.
The amendment was made after you found the booking, whilst I was on hold, which makes sense because there is no need to amend a booking to find a booking. This will go to legal afterwards, the incompetence at SWR assisted travel today has been ludicrous. Now. As I requested from the start, please book the 1st Class wheelchair space between Kings Cross and Leeds, that’s in Coach M, then transfer me to the standard class wheelchair space at Leeds for the final leg to Harrogate.
It will go to legal? Please hold the line.
Holding…
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Hello. Sorry to keep you waiting, I apologise, Mr Paulley… Obviously, this needs to be looked in further for you, and there is not enough time left this evening to look into this correctly for you, so it will be rebooked completely for you tomorrow. Where we will make sure the agent investigates what spaces are available on what part of the journey.
“To make an Assisted Travel booking, contact our Assisted Travel team 24 hours a day, every day except 25 and 26 December”. You are here all night. Go ahead and sort my booking, please.
I am not here all night.
Well, your colleagues are, sort it out, please. I am not leaving the phone until I have a valid booking.
Are you prepared to wait an hour?
An hour? Why an hour? Get on with it now, please. If necessary cancel the whole thing and start again.
You have gone quiet?
Note from relay assistant: I am waiting for her response. We are still connected.
Thank you.
Note from relay assistant: there is no response. Only silence. But we are still connected.
Is there background noise, i.e. are we still attached to a telephone, or is the line completely silent?
Note from relay assistant: the line is completely silent. But we may be just muted.
OK, thank you. Please say: “this call has already lasted longer than it should have done. Your accessible travel plan makes clear that you can book wheelchair spaces on other TOC services, and you say you are open 24/7. Please make this booking.”.
Hello. Sorry to keep you waiting. I will transfer you to somebody who is here longer and will be able to book it for you. Please hold…
Holding…
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Hello. I am sorry that the booking contains errors. What I will do now is set up a case now and pass it onto management, and ask them to investigate thoroughly what happened. I understand that you want to change this booking now. Could you please confirm the journey details and I will be able to arrange it for you?
The journey hasn’t changed. It is on XXXday XX July, leaving Farnham 1328 and arriving Harrogate 1831.
I need ramps at all points, also I need the wheelchair space booking on the LNER portion. 1st Class wheelchair space.
There is an issue at Harrogate that the platform is too short for the train and the 1st Class wheelchair space trails off the end of the platform. As a result, it is only possible to book the 1st Class wheelchair space as far as Leeds. So please book the 1st Class wheelchair space from London to Leeds, then transfer me to the standard class wheelchair space on the same train at Leeds for the final portion to Harrogate. Ramps required at all points.
Right, OK. Please bear with me one moment while I get all of this booked in – then I will come back to you.
OK, thank you. The 1st Class wheelchair space is in Coach M on the LNER, if that helps. Will hold.
OK, perfect…
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Are you aware that we cannot book assistance on the underground from London Waterloo to King’s Cross? So, you will have to make yourself known to a TFL member of staff?
Thank you; yes. What makes it interesting is that in the booking confirmation from SWR earlier this evening they did book assistance on London Underground, which is interesting as I know it is impossible! Thank you.
My apologies for this. As mentioned we will set up a case and investigate. You were advised incorrectly.
Thank you, yes.
Thank you…
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Hello. I am back. Thank you so much for holding there… OK, I am just running through everything with the booking to make sure it is correct. So just to confirm, this booking is for XX July, leaving Farnham at 1358, going to Harrogate via Leeds arriving into Harrogate for 1903.
No, it is leaving Farnham at 1328 and arriving in Harrogate at 1831.
OK… I apologise, please bear with me two moments while I amend this.
OK.
Right…due to the short platform at Harrogate you will receive two separate bookings; one for Farnham to Leeds and the second will be Leeds to Harrogate. Are you OK with that?
Yes, thank you.
I am just actioning this now.
OK.
Thank you so much…
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Right, apologies. Sorry to inform you, however the first-class wheelchair space on that service has already been booked. Are you happy to travel in the standard wheelchair space from – up to Harrogate?
There are two first-class wheelchair spaces and they aren’t booked; they just appear to be booked because Transreport’s Passenger Assist has a bug in it.
The wheelchair space appears available until you attempt to book it, at which point the system throws an error and claims the space is booked after all.
This is a known bug with Transreport’s Passenger Assist, which the wheelchair space has to be booked via alternative means, meaning Journey Planner or Portal.
Please book the space.
OK, I will do that now…
Holding…
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I will have to keep you on hold a little longer while I chat to my team. Is that ok?
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Hello, sorry to keep you on hold for so long. We are still currently unable to book the first-class wheelchair space. However, we can arrange to call you back in the morning when we have completed it… Or is there a preferred contact method? I will make an amendment to the booking so you will get email confirmation of that.
Thank you, I don’t do phone calls in general, and incoming calls, in particular, / call centre calls in particular, due to hearing loss. The best way to get me is to email me on xxxx.paulley@kingqueen.org.uk.
Yes, I have that one… So, to confirm… Are you happy for me to book the assistance without the first-class wheelchair space for now – and then email you in the morning when it has been updated?
Yes, thank you.
Perfect – I’ll get everything booked in now and then will get back to you with two reference numbers…
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OK, I have two reference numbers here… Your journey from Farnham to Leeds is booked under reference PA-XXXXXXXX and your journey from Leeds to Harrogate is booked under reference PA-XXXXXXXX, and your seat from Leeds to Harrogate is coach A, seat A02.
OK, thank you for your help. Good evening now.
My apologies once again for any frustration caused. As per our conversation, I will email you in the morning to confirm that first-class wheelchair space has been booked.
OK, thank you. Goodnight now.
Goodnight.
TL;DR
South Western Railway:
couldn’t find my assistance booking
thought that the text I had typed requesting the wheelchair space booking, was actually text written by the person confirming the booking
put me on hold multiple times, for a total of about 45 minutes
claimed my assistance booking hadn’t been made and was still awaiting staff confirmation, when in fact it had been made and confirmed
hadn’t made any wheelchair space bookings as requested
then booked me standard class when I had requested first
claimed that them searching for my booking would have resulted in me receiving a “Booking Alteration” email
suddenly and markedly changed their tone when I said I would go to legal
claimed there wasn’t enough time left in the evening to sort my assistance booking (their service advertises itself as open 24/7 363 days a year…)
then asked me to wait a further hour on hold
gave me the silent treatment
had requested assistance on London Underground that cannot actually be provided
booked me the wrong trains at the wrong times despite me having given the details in the original booking request and again on the phone
told me that the 1st Class wheelchair spaces were unavailable when this is in fact due to TransReport’s glitch
were unable to overcome the glitch and actually make the booking, at the end of it all – and had to promise to contact me again tomorrow.
All that extra stress…
…to attempt to do what a non-disabled person can do in seconds on their website: make the bookings and practical arrangements to secure their accommodation and travel. It’s quite simply not on, is it?
The above is one small example of the myriad of issues disabled people including me experience when we try and travel: the assistance/wheelchair space booking process is fundamentally broken, causing immense stress, and wasting a huge amount of disabled people’s time and energy, for something that non-disabled people take for granted and which takes seconds.
Legal
The above is obviously morally reprehensible, but it also shouldn’t be like this under the industry’s regulatory and legal obligations.
It’s also illegal under the Equality Act. TransReport, Rail Delivery Group and South Western Railway are service providers under a duty to make reasonable adjustments to practices that make it unreasonably difficult for wheelchair users and other disabled people to access their services, i.e. to travel. They’re also under a duty to provide effective auxiliary services if needed by disabled people.
The (apposite!) precedent in Roads v Central Trains Limited [2004] EWCA Civ 1541, (2004) 104 ConLR 62 states:
the policy of the Act is not a minimalist policy of simply ensuring that some access is available to the disabled: it is, so far as reasonably practicable, to approximate the access enjoyed by disabled persons to that enjoyed by the rest of the public.
Non-disabled people can book their tickets, practical arrangements and seats in seconds, reliably, without difficulty and automatedly, via a number of channels and without requiring human intervention. RDG, TransReport and South Western Rail could make the same possible for disabled people. Why don’t they?
Their failure to do so has caused me significant detriment – wasted my time, made me very angry and I STILL haven’t got the arrangements booked.
Actions required
So, TransReport, Rail Delivery Group and South Western Rail: this blog post constitutes a Letter before Action within the meaning of Section 6 of the Practice Direction: Pre-action Conduct and Protocols.
Unless you comply with my reasonable requirements as specified below within 14 days of this blog post being published, I shall take you to Court with no further notice.
Said requirements consitute:
An open admission that you have discriminated against disabled people through your failure to make your wheelchair space and assistance booking processes easy and reliable.
Legally binding undertakings to remedy these problems, within a specified, prompt timescale. Such undertakings to include:
To sort the bug that is preventing rail assistance booking staff from making some wheelchair space reservations via TransReport’s user interface.
To implement a system enabling wheelchair users to book available train wheelchair spaces interactively and without requiring rail staff intervention.
To sort the multiple other bugs and limitations with the TransReport app and back-end
Compensation commensurate with the precedent set in Vento, as amended.
Addendum
My criticisms of the TransReport app and booking process above are in no way intended as a criticism of the many excellent disabled people who (like me) provided their input and expertise in an attempt to make it as accessible and useful as possible for disabled people. The failures are squarely in Rail Delivery Group’s and TransReport’s lane. I know that the app is a sight more accessible and usable than it would have been without disabled people’s input – and would be even more so if Rail Delivery Group had actually listened.
As the booking is processed further, I shall either add the ongoing situation below or in the blog’s comments.
Addendum next day
A flurry of automated emails from SWR, TransReport and LNER; amongst which:
Your seat reservation in first class from London Kings Cross to Leeds is M:20 has been booked via LNER and the reference that relates to your seat only is; VDXXXXXX, then your journey from Leeds to Harrogate is booking reference PA-XXXXXXXX and, your seat number A02 in standard class and again, your booking reference for the seat only is RTXXXXXX.
(What they mean is, the WHEELCHAIR SPACES have been booked; not seats. Good job I know that isn’t it! Once again, something that could puzzle and concern wheelchair users.)
I feel like I’ve won the blooming lottery! Finally what looks like the actual assistance booking I had requested – it only took an hour on the phone, determinedly knowing the system better than the employees I was speaking to and doggedly refusing to accept anything other than the correct booking. For something that non-disabled people can do in seconds with no stress or arcane knowledge required.
My outward journey is still “Unconfirmed”, however – LNER haven’t processed my booking request sigh.
Screenshot of Passenger Assist app, showing an Unconfirmed journey from Leeds to Farnham.
It has gone over 24 hours without being confirmed, so I used LNER’s Live Chat to get the booking confirmed. This took 10 minutes. Here’s the transcript.
LNER Chat Transcript
Hi and welcome to LNER Chat. My name is Athena and I am a digital assistant.
How can I help you today? Please use the quick buttons below or type your question and I will try to assist you.
Speak to a human
Our live chat opening times are Mon-Sunday, 8am-10pm.
When our agents are live, please allow 2-3 minutes for an agent to join the chat.
Good Evening! You are chatting with Martin today. How may I help?
Hi. I used the Passenger Assist app yesterday to book assistance for a journey, but the assistance still hasn’t been reviewed by LNER and confirmed. Please can you do so? PA-XXXXXXXX
Please bear with me, and I will look into this for you.
OK.
Hi Doug, so that should be confirmed now for you. My colleague who was booking the assistance has had to book E19, E18 for you.
Thank you.
I was expecting it to be confirmed before now; it’s been over 24 hours. It slipped the net?
We were just making sure that everything was correct for you.
…OK.
tl;dr
LNER said that they hadn’t confirmed my assistance and wheelchair space booking, 28 hours after I made it via the app, because “We were just making sure that everything was correct for you.“
I don’t believe this, frankly. They are required to accept assistance bookings with 6 hours notice; why would they leave it 28 hours? If, however, it really is the case that they intentionally left it until I contacted them before they confirmed the booking, then it is a blooming good job that the wheelchair space I needed wasn’t reserved by somebody else in the meantime. Also, how was I to know that I had to get in contact in order for it to be confirmed? and why should I have to? It doesn’t make sense.
It also sounds like they had the usual TransReport Passenger Assist wheelchair space booking glitch: “My colleague who was booking the assistance has had to book E19, E18 for you.“
Booking completed
Finally, 28 hours after I requested the assistance via the app, after speaking to SWR for over an hour and LNER for a further 10 minutes, after chasing two train operating companies because they failed to follow the procedures and thus stuffed up the assistance booking, and after I explained to staff how to achieve the actual bookings because their systems are fundamentally broken, I finally have valid assistance and wheelchair space booking for both the outward and return portions.
All to achieve something that non-disabled people can do in seconds and with minimal / no stress.
I feel like I’ve won the blooming lottery.
And the next day…
An email from LNER:
We’re just letting you know that we’ve got everything sorted for your next journey. I have booked you onto the earlier service of 10:05 on XX July, between Leeds and Kings Cross as, regrettably, the First Class wheelchair space wasn’t available on the 10:45 service.
I obviously spoke too soon: having thought that the booking was finally sorted, somebody has booked duplicate assistance and wheelchair space on an earlier train. In addition to the existing correct booking already made.
Goodness knows where this duplicate came from. He evidently didn’t check whether the booking had already been actioned; also evidently got the TransReport first class wheelchair space booking bug, didn’t realise that all the wheelchair spaces on my intended train are in first class; and didn’t bother booking the rest of my journey to Farnham.
What a mess. For Goodness’ sake. Now I have to cancel this duplicate booking, which I never asked for in the first place.
I have been researching the accuracy of rail station disability accessibility information for several years. The difficulty with inaccuracy of such has been recognised by the Office of Rail and Road: (PDF)
Inaccurate, incomplete or unclear information may result in assistance being booked for a journey that involves a station which proves to be inaccessible to the passenger.
… Bookings are ‘designed to fail’ from the outset due to inaccurate station information.
There are long-standing issues with the station information held on the National Rail Enquiries website that affect prospective passengers and booking agents. The working group estimated that a significant number of the station pages on NRE display some form of inaccurate information.
My research compares data in Knowledgebase / National Rail Enquiries against that published in Train Operating Companies’ accessible travel policies.
So for Britain’s 2,500+ stations, 2,190 (85%) have some item of accessibility data differ between the ATP / DPPP and National Rail Enquiries. For example, of those stations that have information on the provision or otherwise of accessible toilets, 154 (13%) differ between the two information sources – either National Rail Enquiries says there is an accessible toilet and the ATP says there isn’t, or vice versa.
Lobbying Rail Delivery Group
I’ve been emailing the Office of Rail and Road, Train Operating Companies and Rail Delivery Group about this. Here’s an extract from my most recent email to Rail Delivery Group.
DPPP/ATP vs Knowledgebase comparison
I have many thoughts and experiences with Knowledgebase, predominantly through my research into consistency of accuracy in station accessibility feature information between different sources – e.g. DPPPs/ATPs, Knowledgebase and TOC accessibility maps. Like the ORR, I have significant concerns about its accuracy.
Such isn’t an academic exercise: I have had multiple experiences with such information being inaccurate causing me difficulties on the ground.
I attach a spreadsheet showing a comparison of station information from Knowledgebase against that in their DPPPs / ATPs. There are significant differences. Whilst some of these differences may be due to the comparative ages of information – e.g. station features for stations in DPPPs written up to 4 years ago may well have changed – the number of discrepancies is too substantial for this to account for it.
Examples include the 296 stations where the ATP says there’s a disabled toilet but Knowledgebase says there isn’t (have they all been closed since the DPPP / ATP were published?!) and the 42 where Knowledgebase says there is an accessible toilet but the ATP / DPPP says there isn’t.
And many, many, many more. The spreadsheet shows inconsistencies in 2194 of the 2586 stations’ accessibility data. For those 2194 stations at least one element of accessibility data differs between Knowledgebase and the station information in the relevant ATP / DPPP. Many stations have more than one such discrepancy – across those 2,194 stations, there are 6,145 instances where an element of a station’s accessibility information differs between that stated in the DPPP/ATP and that in Knowledgebase. (That’s excluding instances of such information being missing from Knowledgebase.)
Structural errors
More concerning to me is that the structure of Knowledgebase simply makes it impossible for station operators to input accurate information.
Take “Step Free Access Coverage”.
The current Knowledgebase Data Feeds Specification and the Developers Guide for the Stations V4 XML Feed say:
<StepFreeAccess><Coverage>
Coverage of step free access. Contains 1 of the following values: wholeStation / partialStation / allPlatforms / noPartOfStation / unknown.
The RDG Knowledgebase Stations Data Feeds Specification has been updated and re-signed off on a regular basis, and was signed off in 2019.
<xsd:enumeration value=”wholeStation”>
<xsd:annotation><xsd:documentation> The whole station is accessible, including all platforms and ticket office. </xsd:documentation></xsd:annotation></xsd:enumeration>
<xsd:enumeration value=”partialStation”>
<xsd:annotation><xsd:documentation> Parts of the station are accessible. Used when neither allPlatforms nor wholeStation are applicable. </xsd:documentation></xsd:annotation></xsd:enumeration>
<xsd:enumeration value=”allPlatforms”>
<xsd:annotation><xsd:documentation> All platforms are accessible, but not the ticket office. </xsd:documentation></xsd:annotation></xsd:enumeration>
<xsd:enumeration value=”noPartOfStation”>
<xsd:annotation><xsd:documentation> Neither the platforms nor the ticket office are accessible. </xsd:documentation></xsd:annotation></xsd:enumeration>
<xsd:enumeration value=”unknown”>
<xsd:annotation><xsd:documentation> Accessibility details are unknown. </xsd:documentation></xsd:annotation></xsd:enumeration> </xsd:restriction> </xsd:simpleType>
I therefore don’t understand why it is not currently possible for station operators to select “partialStation” or “allPlatforms” – and why all stations are thus arbitrarily classified as having full or no step-free access. The XML data feed specification is signed off year after year, going through a formal review process, and remains with these options in, yet they aren’t actually possible to select; in actual fact only “wholeStation” or “noPartOfStation” can be selected.
One wonders: what is the point in having a formal specification and schema approval process, if the resulting document isn’t accurate nor followed? But more importantly: what is the point of having this crucial information in Knowledgebase, given that its implementation means the information it holds simply can’t be trusted?
Micky Ball and Michael Adlington recognised in 2017 that this needed to be changed. So did Scotrail, who emailed me in 2017 to say:
“ScotRail is experiencing difficulties with updating the ‘Step-free access coverage’ section due to a technical issue with the NRE website, which is only allowing for ScotRail to tick ‘Yes/No’ for this field without the option to edit text. This is an issue that can only be addressed by Rail Delivery Group, which ScotRail has requested be addressed as quickly as possible.”
Other anomalies include: there’s a field for “Station Categorisation”, presumably Step-Free Access Categorisation using the ORR’s definitions – but it’s only filled in for 235 stations (GTR’s), and in any case it only allows a single-character entry, so not “B1, B2 or B3” as described by the ORR.
Every station (all 2,500+) is down as having an “induction loop” – even those that have no ticket offices, audio announcements, or help points, so I question what audio information can be being provided over induction loops at these stations!
“Last Changed” doesn’t update for some stations – e.g. Knowledgebase claims Maybole’s data was last updated in November 2016 yet the Step Free Access Note states “This is a Category A Station” – a categorisation invented by the ORR in 2019.
TOC accessibility managers tell me that they spend considerable time and money surveying access features at all their stations, provide this information to NRE, mass-upload it – then find that the database has been reverted to an earlier version, undoing all the updates, without the TOC even having been informed.
This simply doesn’t work.
Knowledgebase replacement deadline, and interim issues
The Knowledgebase replacement has been promised for many years. I was promised it by the end of 2016. Micky Ball and Michael Adlington promised it by the end of 2017. There have been any number of slipped deadlines and so on.
I now understand that the replacement is not likely to be implemented until the end of 2022? I’d be grateful for any information on this process and deadlines.
I guess the above issues, and many more, show why such a replacement is needed. The problem is: the existing system isn’t viable in the meantime. It has been creaking on for far too long, unloved, unmanaged and left to rot (to say nothing of Stations Made Easy); with work-around after work-around.
The result is that disabled people suffer. I suffer; the frustration of attempting to find accurate information for planning and booking journeys, finding “on the ground” that journeys I wish to complete aren’t actually possible; that I can’t hear announcements or that I can’t go to the toilet and so on. And so do others.
I would argue that the existing system must not be expected to last until it is replaced; especially as the replacement timescale may well slip, given the RDG’s planned Knowledgebase replacement has suffered so many slipped deadlines already (and similarly the Passenger Assist app etc.) It would seem that the ORR are of a similar mind: I have been collaborating with them for their current audit of the accuracy of station accessibility information, and I’m aware of what emphasis they (rightly) place on such.
What can be done about it?
Can I help?
As you have probably gathered, I care about this a great deal. Accurate information about accessibility is every bit as necessary and important as accessibility itself: neither is of any use without the other; and this seemingly dry subject has a real, human, cost on disabled people’s ability to access public transport.
The spreadsheet shows potential inaccuracies in 2,194 of 2,586 stations’ data.
So: what would be practicable? How can I help to ensure the accuracy of information in Knowledgebase until the new version is released? How can I contribute to ensuring the new version is more fit for purpose than the current mess? And how can RDG, as owners of this data, improve this?
Hopefully Rail Delivery Group will respond positively to the email above and actually do something about this egregious and potentially harmful access information provision failure.
