Schedule 17 response to Greater Anglia

20 December 2021

Mr B Davies
Customer Service Project Manager
Greater Anglia
11th Floor
One Stratford Place
Montfichet Road
London
E20 1EJ

(sent via e-mail)

Dear Mr Davies

Proposal to permanently close Harlow Mill ticket office

I am writing on behalf of London TravelWatch in response to the above proposal from Greater Anglia. This proposal follows the closure of the ticket office at Harlow Mill since 20 November 2020 for safety reasons due to the identification of structural defects.

Summary of consultation responses

We have received 5 responses from individuals.

All respondents are opposed to the proposals. The issues raised are detailed below.

Ensuring widespread and easy access to the purchase of rail products

Respondents to the consultation expressed concern that not all passengers can use ticket vending machines (TVMs).

One respondent explained that the 50% and 34% concessionary discount tickets for wheelchair users staying in their chairs, blind and visually impaired people are currently available at the ticket office but not from station TVMs. Without a ticket office, disabled people could potentially pay more for their tickets.

Concern was also expressed that as Harlow Mill only has one TVM, there would be no way to collect tickets if it breaks. It was suggested that a second machine be added if the ticket office remains closed.

Greater Anglia have supplied data showing extremely high TVM reliability. However, we call for you to ensure that you notify the Department for Transport, possibly through Transport Focus, when no machine is available, as would be done for a ticket office closure.

Greater Anglia have also advised that a decision to include a second TVM at the station would need to be driven by customer numbers.

We note that there is a help facility on the TVM that connects with Greater Anglia’s Customer Service Team in Norwich. If a passenger was about to travel and wanted to purchase a ticket not available on the TVM, the Team would identify a suitable location en route where the transaction could be fulfilled. The Team would also be able to provide options for advance bookings. Greater Anglia have advised that the number of unavailable tickets would be extremely small and they have no instances on record of difficulties in this respect.

Safety, security and accessibility

Concern was raised that closure of the ticket office would worsen passenger safety, security and accessibility. One respondent noted that the lack of staff presence contributes to more fare evasion and anti-social behaviour.

Should the permanent closure of the ticket office be agreed to, Greater Anglia have committed to replacing the current staffing model with a 25 hours per week Station Host role. Their responsibilities would include customer assistance with the TVM, customer information and advice, assistance to customers with reduced mobility and a responsibility for station standards – reporting faults etc. The working hours for this staff member on weekday mornings will cover the times of greatest footfall at Harlow Mill.

Greater Anglia have confirmed that they envisage that the Host would mainly operate from the core facilities on the London bound platform (the direction of travel of the vast majority of customers during the morning). The Host will, however, be fully mobile and able to provide advice and assistance in all parts of the station including the car park and drop off areas.

We have reviewed the Harlow Mill station information poster which explains what passengers should do if they need help at times when the station isn’t staffed. This includes contact details for the British Transport Police and for passengers requiring assistance on their journey.

Greater Anglia have also advised that there would be a substantial cost in providing a new ticket office and that this cost would impact on their plans to provide other, new facilities at the station.

Ticket sales volume

Greater Anglia have provided ticket sales data which covers the weeks immediately prior to the pandemic in March 2020, and also in October/November 2020.

Please note that the recently updated Secretary of State’s Guidance on Schedule 17 states that ticket issues data should not be considered ‘since the Covid-19 pandemic lockdown on 23 March 2020’. Accordingly, the ticket sales data provided for October/November 2020 has not been considered as part of our response.

The Secretary of State’s definition of a “busy” ticket office is one in which there are an average of 12 ticket sales per hour. We have reviewed the sales data for the period in which you propose to close the ticket office i.e. 06.45 – 11.15, Monday to Friday. You acknowledge that during much of this period ticket sales are at, or above, the 12 ticket sales per hour and so do not meet the Department for Transport guidelines for closure.

However, given the exceptional circumstances of the ticket office being currently closed and the substantial costs in opening a new ticket office, we do not object to the proposed permanent closure of Greater Anglia’s ticket office at Harlow Mill.

Although we do not object to the closure, this would be subject to the implementation of the mitigation measure of employing a Station Host during the busiest times on weekdays to help passengers and provide reassurances about safety and security. Greater Anglia should also continue to monitor usage of the existing TVM and, if appropriate, install a second TVM (or an upgraded TVM with enhanced functionality).

Please contact me if you wish to discuss any of the above.

We will be sharing this submission with our colleagues at Transport Focus.

Yours sincerely

Trevor Rosenberg

Policy and Advocacy Officer