
ALT Six examples of Rail Delivery Group's Google ads, appearing as Sponsored search results on Google for searches relating to search terms: consultation, ticket offices, digital ticketing, changes to ticket offices, proposals for stations, closures to ticket offices. Though the headlines of the ads differ, the text is the same in each: "Train operators have launched a public consultation on proposed changes to ticket offices. Operators are proposing more customer facing roles."

ALT The Schedule 17 consultations are inadequate and unaccountable. Consultations on ticket office closures are set to take place under Schedule 17 of the Ticketing and Settlement Agreement (TSA), a contractual relationship between the Rail Delivery Group and train operators. Going forward with the process at this time not only represents a major risk to regulatory coherence, it betrays key promises made by the DfT on Great British Railways, especially the promised ‘National Rail Accessibility Strategy’ consultation, and a ‘National Accessible Travel Policy’ to be enforced by the ORR. It is impossible to see how the DfT can be meeting its public sector equality duty, when it is about to launch a fragmented, unregulated process - on a matter of national policy that is in desperate need of statutory consultation.

ALT The public should be made aware that any promises made about moving staff ‘in front of the glass’ lack a regulatory or contractual basis, and should therefore be considered meaningless. Schedule 17 is also the mechanism that lists operators’ obligations for ticket office staffing hours, so, when completed, the consultation process would also remove all remaining transparency over staffing numbers and locations. The only possible advantage for the government and Rail Delivery Group of rushing through ticket office closure plans at this time is to grant themselves more flexibility to make ‘stealth destaffing’ changes later; for example, through recruitment freezes, redundancy packages, and the increased use of agency staff. We estimate that over half of the 1000 offices reportedly listed for closure are currently staffed only by ticket office staff. If the government succeeds in removing Schedule 17 obligations for staffing at these locations this creates the flexibility for over 500 mor






















