Written evidence submitted by Trainline.com Limited (RPE0201)

 

 

SUBMISSION TO HOUSE OF COMMONS TRANSPORT COMMITTEE INQUIRY

“IMPROVING THE PASSENGER EXPERIENCE”

 

 

1.              Executive Summary

 

Trainline welcome the opportunity to submit written evidence to the House of Commons Transport Committee inquiry “Improving the passenger experience”. In particular, Trainline support the focus of the Committee on the passenger experience. While important, political and policy discussion around the UK rail sector tends to focus on structural, organisational and infrastructure considerations, often crowding out important issues affecting rail passengers on a day-to-day basis.

 

Trainline believe that major improvements to the rail passenger experience can be realised quickly and at relatively modest cost, through a focus on those issues that are most visible and important to rail passengers – modernisation of ticketing, easier access to the best fares and provision of better information about their journey. Trainline make the following key points in this submission: 

 

 

 

 

 

There is already an emerging consensus on many of these areas between the Department for Transport (DfT), the rail industry as represented by the Rail Delivery Group (RDG) and other important stakeholders such as third party ticket retailers, including Trainline. The work of the Committee in this inquiry will be invaluable in supporting existing industry work and bringing forward solutions to help the passenger realise a more efficient, effective and enjoyable journey.

 

2.              Trainline

 

Trainline is the largest independent provider of rail tickets in the UK and Europe. Our mission is to help people make smarter journeys every day, and save them time, hassle and money. Trainline is entirely independent of all Train Operating Companies (TOCs).

 

Trainline operates under a Third Party Investor Licence granted by the Association of Train Operating Companies (ATOC). We sell over £1.6bn worth of rail tickets each year and have some 28m customers per month visiting our website and using our mobile app. We have historically been in the top two travel app downloads in the UK. Trainline is the fifth largest UK e-commerce platform and we employ around 400 people across our corporate HQ in London and operations centre in Edinburgh, mainly in higher value added technology and development roles. In March 2016 Trainline acquired Paris-based Captain Train, to create the new leader in digital rail ticket retailing across Europe.

 

Trainline sell to all types of passenger, from regular commuters taking short journeys to occasional long-distance travellers, and everything in-between, covering leisure and business markets. The millions of passengers served by Trainline each year provide us with a unique understanding of rail travel in the UK and Europe. For these reasons, we have passenger insight that is comprehensive, independent and not limited by franchise or investment horizons. At all times, our focus is on the passenger and serving their needs, backed by a deep understanding of their requirements.

 

Led by the insight provided by our millions of customers, Trainline has constantly innovated so that passengers enjoy the best possible travel experience. As an independent retailer, Trainline can take a longer term, holistic view of rail passengers’ needs. Trainline was central to the development of key rail ticket innovations; Ticket on Departure, self-print ticketing, the first mobile app in 2009, and the first retailing app in 2010. More recently, Trainline has helped roll out m-ticketing, where we have been at the forefront of the successful ‘Flexible m-ticket’ trials in the North of England during 2015 involving five TOCs (Virgin Trains East Coast, Virgin Trains West Coast, CrossCountry, Northern and First TransPennine Express), along with introducing real-time platform information and delay alerts on mobile apps, reducing ticket purchase flow to three clicks, and introducing new payment methods including PayPal and Apple Pay. 

 

3.              Specific Areas Raised by the Committee

 

3.1              Information provided to passengers before, during and after rail journeys, including information provided at stations, in trains and via National Rail Enquiries, operators' websites and online apps (excluding in relation to the process for claiming compensation for a delay/cancellation)

 

Research conducted by Trainline has identified that the single biggest barrier to passengers choosing to travel by rail is uncertainty over whether they are obtaining the best possible fare for a particular journey, with largest proportion of nearly 2500 respondents in a Trainline customer survey supporting this point. At present it is not possible for a passenger to have full confidence that they will always have access to the best possible fare whether they are buying direct from the TOC in question, from another TOC or from a third party retailer such as Trainline.

 

This view is backed up by the Office of Road and Rail (ORR) who discovered that some 50% of respondents to a recent study agreed that it is a lottery if they found the best fare and 43% said the fare system is too complex. Further, Transport Focus research in 2015 revealed that, for most people, value for money was the key factor in their choice of ticket and yet the proportion of passengers satisfied with the value for money of the price of their ticket nationally was only 45%. Trainline believe it is crucial that passengers should have absolute confidence that they will be sold the same fare (i.e. the best fare) for their journey regardless of where they choose to purchase their tickets, in order to ensure passenger trust and confidence in booking online. It is neither fair that passengers are exploited depending on where and how they choose to purchase their ticket online, or a good use of passenger time searching online across multiple sites in order to find the best fare.

 

A key driver of this confusion is the small number of fares retained by TOCs for sale exclusively via their own websites and which have a disproportionately large negative impact on consumer belief that they can always obtain the best fare, whatever online platform they use to book their journey.

 

Regulation allows TOCs to withhold certain temporary and promotional fares, and discounted fares from other retail parties. The removal of such obvious anomalies would have a profound impact on improving passenger confidence in booking online and would remove loopholes that mean c.20% of the market supplied by third party retailers are not locked out of obtaining the best deal at all times. 

 

Accordingly we would request allowing all retailers access to all promotional, discounted and standard fares from TOCs in order to give consumers confidence to travel by rail more often. To this end, Trainline support the policy proposal to introduce a right for passengers to demand the best fare for their journey. We support this initiative but strongly recommend that for any such regime to be effective, parity of access to fares and products to all retailers is absolutely essential.

 

3.2              Ticketing, including overcoming obstacles to the more widespread delivery of "smart-ticketing" and part-time season tickets

 

Trainline strongly support the move towards more modern, customer-focused ticketing as envisaged by the Department for Transport (DfT) and endorse comments made by Rail Minister, Claire Perry MP in her 26 January 2016 speech to the Transport Ticketing and Passenger Information Conference:

 

“If smart ticketing is to become established on our railways, it will mean the death of the tangerine ticket; the familiar orange magstripe paper ticket that has served Britain’s rail customers for thirty years. A ticket that has done its job well, but now seems woefully inadequate for the future — especially for an industry focused on customer service.”

 

At present the UK rail sector does lag some way behind their peers in other comparable countries and also other sectors of the domestic transport industry. In Germany, 100% of Deutsche Bahn regular rail tickets are available as m-tickets as well as PDFs and it is up to the customer to select their preferred method of fulfilment. We understand that all rail ticketing in Sweden is now available as m-ticketing. In UK air, operators such as British Airways, easyJet, Virgin and Flybe all offer m-ticketing. In UK coach, operators National Express, City Link and Megabus offer mobile fulfilment. 

 

It might be helpful to add definition as to the rail smart ticketing models now available in the UK:

 

‒         Mobile-ticket (or “m-tickets”): The model with by far the greatest market penetration to date, with around one-third of all journeys now available through m-tickets. This operates by an electronic ticket being sent to the smartphone of a passenger and the m-ticket brought up on screen of the smartphone and presented for scanning by the passenger at the gateline or with a handheld device used by a member of train staff for verification. A physical substitute is also available if necessary, where a printed receipt roll containing a barcode can be used where required.

 

‒         ITSO Smart: Based on the UK transport-specific Integrated Transport Smartcard Organisation (ITSO) standard, ITSO smartcards are being gradually introduced in the UK. There is already wide acceptance of ITSO on the UK bus network, through a range of regional initiatives (including London as well as the proprietary Oyster card). At present acceptance on the rail network is low with only limited (sub 20%) uptake of season tickets across London and South East (L&SE) commuter TOCs. ITSO smart has proved a complex and costly technology to implement, which has limited rail market penetration.

 

‒         Contactless EMV (cEMV): This model provides the ability to pay for a journey by scanning a debit or credit card issued by Europay, MasterCard, and Visa (EMV) equipped with the ability to facilitate contactless payment. This transit ticket model has been notably and successfully pioneered in London by TfL and is now used for c.30% of contactless journeys on TfL. However, there has been no adoption elsewhere on UK rail and this remains limited only to journeys using the TfL ‘pay-as-you-go’ infrastructure in Greater London.

 

Trainline believe that the migration from tangerine paper tickets to m-ticketing is necessary to keep pace with consumer habits and preferences and deliver a better travel experience for passengers through removing the need to queue at ticket offices or vending machines. A survey by Trainline found that c.20 mins is allowed by customers in a journey to collect their ticket from the station. The factoring in of this time represents a very significant and entirely avoidable consumer detriment.

 

Certainly the transition to m-ticketing would be warmly received by rail passengers. As cited above, Trainline was closely involved in the hugely successful recent ‘Flexible m-ticket’ trials in the North of England during 2015 involving five TOCs (Virgin Trains East Coast, Virgin Trains West Coast, CrossCountry, Northern and First TransPennine Express). This trial demonstrated very high levels of satisfaction with m-tickets, as 97% of passenger who took part in the trial declared that they were either “very satisfied” or “satisfied” with using m-tickets.

 

It is also clear that the expansion of m-ticketing will facilitate the introduction of a wider range of rail tickets and products designed around the needs of the passenger, with the ability for the rail industry to reward frequency and off-peak travel in order to more efficiently manage capacity.

 

Trainline welcome the constructive and cooperative approach currently being taken by DfT and RDG to reach a consensus over the plan for rolling out smart ticketing in the UK. While the rapid and growing market penetration, proven and easily adoptable technology, and DfT and RDG backing, make m-ticketing the clear first mover in UK rail smart ticketing, there is likely to be an evolution in smart ticketing in the coming years. Our own analysis suggests that a roadmap towards the retirement of paper tickets by 2020 would likely need to follow the following three steps:

 

(i)              M-ticket/barcode

 

 

 

(ii)              ITSO Smart

 

 

 

(iii)              Contactless EMV

 

 

While the journey from ‘dumb’ paper ticketing to ‘smart’ ticketing technology should be consumer led rather than the result of a centralised decision to ‘pick a winner’, it is welcome that the DfT and RDG are working closely to establish a strategic vision to meet consumer aspirations. The rapid growth of m-ticketing across the UK, from 17% adoption in February 2015 to an envisaged 59% adoption by February 2017, and the positive feedback from passengers in the recent North of England m-ticket trial, does demonstrate the most advanced form of smart ticketing is m-ticketing and rolling this out nationwide would naturally seem to be the immediate priority for the industry.

 

3.3              In-train facilities, including on-journey Wi-Fi and power

 

It is entirely understandable that rail passengers expect access to Wi-Fi and any related content and power on their journey. At the very least, rail passengers should know whether the journey they are booking includes these facilities, to enable them to make informed travel decisions.  However, greater levels and quality of data could delight customers when presented in a user-friendly and timely manner, raising the perception of value of rail travel.

             

Trainline firmly believe that there should be a requirement on TOCs to provide all relevant information and these facilities to passengers, wherever the journey is booked, as part of a greater provision of data to help inform consumers.  In order to ensure this occurs, data should be made freely and readily available by TOCs to other market participants, including third party ticketing retailers (an ‘open data’ principle).

 

For example, seat maps for trains that are not currently universally available in a format which lends itself to mobile usage, and this would address key customer concerns for travellers (especially wanting to travel with business colleagues, friends and family). 

 

Other data requirements would include better access to an upgraded reservations systems, more granular/regular station footfall data (making cities “smarter" in real time) and live feeds of when a ticket is scanned (barcode or collect).

 

 

 

3.4              Performance measures in relation to passenger experience, including passenger survey methodologies

 

Trainline would make only the general point that moving passenger surveys online would enable both a wider cross section of passengers to partake and deliver a greater depth of data by which to help TOCs provide a better service to passengers.

 

 

3.5              Mechanisms to hold operators to account for poor performance and spread the best practice across the industry

 

One powerful means of holding TOCs to account for poor performance is through passenger rail compensation, most notably the ‘Delay Repay’ scheme. However, as noted by the ORR in their February 2014 Passenger Compensation Report, three quarters of rail passengers are unaware of their compensation and refunds rights. Simplifying this process by permitting the retailer through whom a passenger has purchased a ticket to provide a ‘Delay Repay’ compensation service would go some way to improving this position and providing a financial disincentive for poor service provision.

 

All rail passengers should have direct access to this scheme and given that c.20% of tickets are retailed by third party retailers, these retailers must be permitted to provide passengers to whom it has sold a ticket for a delayed journey with a ‘Delay Repay’ compensation service on the same basis that TOCs currently can. The effect of this would be that a passenger need only deal with one party throughout the whole sale and after-sales process. In most other retail contexts, consumers expect to be able to deal with the retailer that sold them the product in the event of after-sales issues arising. At present, this capability is only offered by the TOCs, rather than via the channel that the passenger purchased, to the detriment of passengers.

 

4.              Conclusion

 

Trainline welcome the focus of this inquiry and look forward to providing additional evidence to the Committee as these important issues are considered further throughout the duration of the inquiry.

 

25 May 2016

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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