Written evidence submitted by Transport for London (RRB0052)

Please find below Transport for London’s submission in response to the Transport Committee’s call for evidence as part of the pre-legislative scrutiny of the Government’s draft Rail Reform Bill.

While we are supportive of the establishment of an Integrated Rail Body, we are however disappointed with the pace of progress that has been made to date on rail reform. The Williams Review was established in September 2018, but progress since then has been limited over the last six years.

We would like to see the concerns set out below resolved, preferably through revisions to the draft legislation before a Bill is introduced to Parliament, but as a minimum through policy commitments made in guidance to the Integrated Rail Body.

We are grateful for the opportunity to share these comments. Please do get in contact should you have any questions.

About Transport for London (TfL):

London is a rail ‘super hub’ and is more dependent on rail than any other city in the country. It is estimated that over 70 per cent of all rail travel (including London Underground) in Great Britain is to, from, or within London. We are responsible for the running of over 1,000 trains on our network, the maintenance of over 760km of rail and Underground routes and ensuring that millions of people move around the capital safely every day. The Underground alone has 11 lines covering 402km and serving 272 stations.

Response to call for evidence:

Rather than responding to the individual questions in the call for evidence, we have set out our short response below.

We welcome further moves towards the establishment of the Integrated Rail Body (IRB). It is critical that the rail industry has clear strategic direction to ensure that it can fulfil its full role in the transport sector and support delivery on important policy objectives such as decarbonisation.

However, we do still have some significant concerns about how the IRB will operate in practice. These are set out below.

Relationship between regional transport bodies and the IRB

The Government has still not provided further details or clarity on the relationship between sub-national transport bodies such as TfL and the IRB, or the need for the IRB to pay due regard to the policies of the Greater London Authority (GLA). It is important that these matters are recognised and addressed so we can contribute to the development of the rail network in London which is critical to the ongoing functioning and growth of the capital.

We have a proven track record of making rail services better and more reliable and remain committed to improving rail services through rail devolution as detailed in the Mayor’s Transport Strategy. We need to ensure that the process for further devolution of control over rail services in London is clearly set out so it can be progressed in future, delivering further improvements for customers and building on past successes such as those delivered by the London Overground (LO).

Network access considerations for freight and passenger services

The ORR is still required to “have regard” for the IRB’s access policies when making decisions concerning network access. We would be concerned about the potential impact on TfL in terms of capacity allocation given the IRB’s stated aims of increasing rail freight volumes and promoting the services offered by their own operators.

Freight is key here given that there is already heavy usage of many of our LO and Elizabeth line routes by freight services. There remains a significant risk that we could lose capacity to the freight sector under such arrangements, requiring us to reduce service levels and/or restricting our ability to plan for additional services. This could undermine the value of the significant investments we have previously made in train and infrastructure upgrades to deliver the LO and Elizabeth line networks, reducing the likelihood of TfL and similar bodies making such investments in future. This could in turn limit the development of the network in urban areas which would be to the disbenefit of passengers. We remain of the view that decisions on network access should be made independently of funders using clear, transparent and quantifiable criteria.

March 2024