Dear Mr Harris
1) Bridge Strengthening:

Thank you for your letter of 2nd November ref. TH/024715/06 and for your reply to Paul Burstow MP concerning this topic.

I was aware that the costs of work in connection with bridge strengthening was shared between local authorities and Network Rail but going from reports in the transport press, there does not appear to be a standard contribution from either party with Network Rail being reported to have paid the lion’s share of the costs in some cases.

I am therefore surprised to find that there is no obligation upon Network Rail to provide funds other than to maintain road bridges to be able to carry 24 tons.

This poses a question related to the lack of a level playing field for road and rail funding. Why should the rail industry still be required to maintain public road bridges to any standard when this should logically be the sole responsibility of highway authorities and similarly, why should the railways be burdened with the full cost of operating and maintaining level crossings for the safety and benefit of road users as well as measures to protect rail users from a growing number of irresponsible road users?

2) Closure Procedures:

My main reason for writing on this occasion is to express our deep concern about measures contained in the Railways Act 2005 Provisions for Closures and Minor Modifications.

In March 2006, on behalf of Railfuture, I submitted a response to the consultation on these provisions drawing attention to a number of concerns which I am aware are shared with a large number of stakeholders including Passenger Focus. A copy of our submission can be made available if you wish to see it.

Now that the DfT has completed its deliberations over this consultation, it would seem that only one concession to objections has been made which now places greater responsibility for closure decisions upon the Office for Rail Regulation but with the proviso that non-quantifiable benefits must also be considered.

However, the guidance still specifies the catchment area from a station as 800 metres from non car owning households in urban areas. This is inadequate as there is ample evidence of rail users walking a mile or more to a station.

Annex D still reaches the wrong conclusion in deciding that Option 3 (station closures and reduced service) would be the preferred choice due to a number of incorrect assumptions used in the modelling.

For example: Option 4: Strangely, the guidance claims there is no evidence to show that Community Rail Partnerships have increased passenger numbers but assumes there would have been some cost reductions.

In reality, precisely the opposite has happened with some quite dramatic passenger growth on CRP lines including 192% on Norwich- Sheringham and 170% on Oxted- Uckfield services. The Association of Community Rail Partnerships has well-documented evidence of CRP performance throughout the country which could have been provided had the DfT enquired.

On the other hand, costs have not yet been reduced simply because maintenance procedures more appropriate for lightly used routes have not been implemented to date.

It is clear that Option 4 would have been the preferred choice had this information been used.

Option 2: (Route closure and bus replacement) The guidance suggests that only two single-deck buses costing £197,000 at 2004-05 prices would be required to replace an hourly train service. It also wrongly assumes the bus would take 57 minutes to complete a 47 minute journey by rail when in reality it would be more likely to take 65 to 70 minutes.

In any case, a three-minute turnback period would be insufficient to allow for out of course delays and natural breaks for on-board staff and therefore three buses would be required to provide an hourly service.

Furthermore, the guidance fails to note that the service life of buses is less than half that of trains on average and therefore six buses would be required to replace two trains over their service life.

The guidance also overlooks the quite significant additional road maintenance costs that would be caused by modal shift to the car and particularly buses.

These factors would significantly affect the BCR for Option 2 and put it even lower down the pecking order.

Given that past studies have shown that only about one third of rail passengers would switch to replacement bus services while most would switch to the car, thereby increasing road congestion, pollution and accident risk, it is perhaps surprising that Option 2 was considered at all except to show that it would perform poorly.

The guidance acknowledges the importance of mothballing closed rail routes but also says the value of land for alternative uses should be considered. Such value is at best speculative.

Most outrageously from an environmental view point, the guidance states that where a long-distance rail service is affected by a closure, aviation can be considered a suitable alternative. This suggestion almost beggars belief.

The condition that closures may be considered where the BCR for retaining a service falls below 1:5 remains in the guidance in spite of calls for the BCR to be reduced to 1:1 since any figure above this would imply that a quantifiable benefit exists.

Furthermore, the inclusion of the value of fuel tax revenue generated by a rail closure will create conflicting interests. For example, if the Chancellor were to restore the fuel tax escalator in order to cut carbon emissions, a fresh wave of rail closures would become attractive to the Treasury which would in turn produce a negative environmental impact.

Turning this on its head, given that aviation fuel is tax free, there must be a strong case for replacing air travel with more rail services rather than less of them, but this strangely does not seem to be on the Government’s balance sheet.

We believe that the purpose of this guidance was intended to make rail closure proposals more transparent and fair but judging from the anomalies identified above, it would seem that it has also been designed to make closure proposals easier to justify and implement.

Given the apparent disregard for the views of consultees, one feels obliged to query the purpose of this consultation.

Finally, we also note with dismay that, in spite of a large number of objections, the DfT is to press ahead with its proposed cuts to Cross Country services from the North West to the South coast and South West.

At our meeting in October, you asked if we thought the Government was trying to lose an election? In view of the foregoing, we feel increasingly that we could be forgiven for thinking the answer is yes.

With this in mind, we would ask for a further meeting with you to discuss these concerns at the earliest opportunity in the new year.

I look forward to your reply

Writing on behalf of Mike Crowhurst, Railfuture national chairman


Yours sincerely


Norman Bradbury


Secretary, Policy Lobby & Campaigns Committee