Submission to the Future of Transport Regulatory Review

May 2020

FUTURE OF TRANSPORT REGULATORY REVIEW CALL FOR EVIDENCE RESPONSE FROM THE RAILWAY INDUSTRY ASSOCIATION (RIA) 1. INTRODUCTION This submission constitutes the response from the Railway Industry Association (RIA) to the above call for evidence published on March 2020.

2. BACKGROUND TO RIA 2.1

RIA is the trade association for UK-based suppliers to the UK and world-wide railways. It has over 300 companies in membership covering all aspects of rolling stock and infrastructure supply and covering a diverse range of products and services. As well as most of the larger, multi-national companies, 60% of RIA’s membership base is comprised of SMEs.

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The Oxford Economics 2018 report shows that the UK rail sector contributes annually over £36 billion Gross Value Added (GVA) to the UK economy, employs 600,000 people and generates £11 billion in tax revenues. For every £1 spent on rail, £2.20 of income is generated in the wider economy, meaning rail is not just an important sector, but it is also crucial for UK plc, its economy and connectivity. Rail has been a growing industry with the numbers of rail journeys expected to double in the next 25 years, following a recovery from the Coronavirus epidemic, along with significant growth in rail freight traffic. The full report Oxford Economics report can be accessed here.

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RIA provides its members with extensive services, including: • • • • • •

Representation of the supply industry’s interests to Government, Network Rail (NR), TfL, HS2, ORR and other key stakeholders Providing opportunities for dialogue and networking between members, including several Special and Technical Interest Groups Supply chain improvement initiatives Provision of technical, commercial and political information every week Export promotional activity, through briefings, visits overseas, hosting inwards visits Organising UK presence at exhibitions overseas.

EXECUTIVE SUMMARY The DfT's Future of Transport Regulatory Review considers road, maritime, air and cross-cutting themes, focusing on Micromobility, Buses, taxis & private hire vehicles, and Mobility as a Service (MaaS) platforms. The consultation only very lightly touches on the rail industry, mentioning that there are two initiatives (Joint Rail Open Data Action Plan and Rail Sector Deal) in place to open and digitise relevant data across modes. MaaS success will be driven by digitalisation and the railway industry needs to work together to ensure that rail services are part of the core network of the future of transport. The Review does not consider transport infrastructure.

The Railway Industry Association thinks that rail should be central to any Future of Transport regulatory and strategic discussions and deliberations. Our four key asks are: •

That Government should use its regulatory and contractual powers to remove barriers and unlock open data across the rail sector.

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•

In order to drive innovation and creativity Government should introduce interoperability standards for data sharing, ticketing, and fares. These standards should be aligned across transport modes.

•

That open data requirements should include ticketing and fares; on board assets, facilities & services; and wayfinding to, from and through stations.

•

To ensure that when setting transport policy rail, as the most efficient/low carbon highdensity commuter and long-distance form of public transport, is central to the implementation of MaaS.

3. SCENE SETTING INTRODUCTION 3.1

The DfT's Future of Transport Regulatory Review considers road, maritime, air and crosscutting themes, focusing on Micromobility, Buses, taxis & private hire vehicles, and Mobility as a Service (MaaS) platforms. The consultation only very lightly touches on the rail industry, mentioning that there are two initiatives (Joint Rail Open Data Action Plan and Rail Sector Deal) in place to open and digitise relevant data across modes. MaaS success will be driven by digitalisation and the railway industry needs to work together to ensure that rail services are part of the core network of the future of transport.

3.2

The Railway Industry Association thinks that rail should be central to any Future of Transport regulatory and strategic discussions and deliberations. Our objectives are: • • •

To secure national standards for rail data sharing, ticketing, and fares.

Open access to rail data.

Rail interoperability with all transport modes.

3.3

For rail, MaaS will have the greatest impact (positive or negative) to Train Operating Companies (TOC). The opportunity for rail is to be at the core of making MaaS as success.

The risk for public transport is that rail operators are not yet fully embracing MaaS. The risk for the rail industry is if a super aggregator, such as Google or Amazon, enters the market and takes control of the direct relationship with the customer – collecting and aggregating personalised information about each customer and offering travel planning, booking and payment options. TOCs then become wholesalers of rail journeys, without direct impact to the travelling customer, which will devalue rail services and impact the taxpayer as the cost of the rail industry rises. .

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The rail suppliers, working together with TOCs, can ensure the rail industry is ready to join MaaS platforms as a fully integrated and viable partner, but for this to happen the whole industry needs to work together openly and collaboratively. However current commercial models inhibit this.

4. RAIL DATA STANDARDS 4.1

There is already extensive data available which could allow rail suppliers to build comprehensive rail/multimodal journey planning and booking tools. The biggest challenge, however, is the inconsistency of this data and its sources. The Joint Rail Open Data Action Plan states that most rail datasets are published without formal standards or service level agreements, which means that the timeliness and quality of data can vary greatly.

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The government promised to consider how to implement rail data standards and align them with the wider transport open data agenda.

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RIA ask – that Government should use its regulatory and contractual powers to support open access to data. That it should expedite work on rail data standards and align such standards with the wider transport open data agenda.

5. OPEN ACCESS DATA 5.1 2/6

Currently, rail data feeds are derived from three primary engines:

• • • 5.2

Darwin, the GB rail industry’s official train running information engine, providing realtime arrival and departure predictions, platform numbers, delay estimates, schedule changes and cancellations.

Knowledgebase, the content engine and database of the National Rail Enquiries website, containing static and real-time information, such as station facilities, service disruption, and engineering work.

Online Journey Planner, the engine used to plan routes, calculate fares and establish ticket availability on National Rail Enquiries digital channels.

There are other data sources available, mainly sharing train positioning and scheduling data.

For rail to be fully integrated in MaaS platforms more data needs to be made available on open access platforms mainly on: • • •

Ticketing and fares On board assets, facilities and services Wayfinding to, from and through stations

5.3

RIA understands that there are commercial considerations in place which currently inhibit sharing of ticketing and fares data, but this is essential and, currently, a key barrier for the development of fully integrated multimodal journey planning and booking tools.

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RIA ask – to continue working on open access rail data initiatives (as above) and expand them to include ticketing and fares; on board assets, facilities & services; and wayfinding to, from and through stations.

6. RAIL INTEROPERABILITY 6.1

Many currently available MaaS platforms do not include heavy rail (light rail is available on some platforms). The danger is that regional and intercity rail will be excluded from active participation in creating MaaS platforms and will not be offered as part of a sustainable travel option for users. To be competitive and cost effective MaaS platforsm and IT systems need to be interoperable.

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In a poll run by RIA during the Unlocking Innovation – Digital Journeys for Rail Passengers and Freight webinar, which took place on 23 April 2020, 63% of webinar attendees, consisting mainly of UK rail suppliers, have said that commercial barriers are one of the biggest blockers for railways to join MaaS environment. o

Do you think railway should be part of the MaaS environment?

▪

o

Do you think the railway is ready to be part of the MaaS environment?

▪ ▪

o

100% yes

18.75% - yes 81.25% - no

What is the biggest barrier for railways to join MaaS environment?

▪ ▪ ▪ ▪

36.84% - Technological 26.32% - Regulatory 63.16% - Commercial 47.37% - Behavioural

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As mentioned in the previous section on Open Access Data, access to fares and ticketing information is essential, yet the biggest barrier, for rail to become fully interoperable with other transport providers.

6.4

Currently commercial considerations inhibit data sharing – however open data is not the same as free data. In order to deliver MaaS ambitions in full, Government will need to require open access to data so that it can be marketed effectively thereby driving

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innovation and progress. Citymapper use of mobile phone data is a successful example of such commercialisation on data assets.

6.5

RIA ask – to ensure any and all initiatives on open access rail data are interlinked with other transport initiatives, such as the Bus Open Data Service, requiring bus operators to provide open, accurate and up-to-date data (timetable, fares and live location) data.

If you would like further information, please contact Techinal & Policy Manager Milda Manomaityte at milda.manomaityte@riagb.org.uk, or call 020 7201 0777.

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7. SUPPORTING RESOURCES 7.1

In August 2018, the Government launched the Joint Rail Open Data Action Plan, setting out the following actions that would benefit multi-modal transportation and intelligent mobility: • • • • •

• • •

By June 2019 to create a clear industry-wide rail information governance framework that will take commercial concerns into consideration.

Develop an industry agreed definition of commercially sensitive data by October 2018.

By December 2019, to publish, maintain and update open data catalogue.

By April 2019, each rail entity to take review and negotiate commercial contracts with suppliers who manage and maintain their data and to ensure franchise agreements enable this.

To explore the feasibility of the use of application programming interfaces (APIs) for sharing data that is time-sensitive amongst other initiatives to allow easier access to industry data during Control Period 6 (2019 to 2024) — this work will begin in April 2019.

By September 2019 to create a single point of entry for Rail Delivery Group’s and Network Rail’s open data portals.

By June 2019 to align rail data standards with the wider transport open data agenda.

By July 2019 to work with industry to develop a financial vehicle to incentivise TOCs to release data.

7.2

The Rail Sector Deal will transform the use of data to improve operations and customer experience by establishing a data platform to securely share rail industry data. The data platform will enable rail industry data to be shared widely across different modes of transport and infrastructure systems, enabling innovation and new customer focused products and services to greatly enhance passenger experience and door to door travel as well as more effective movement of goods and reduced costs. The industry will also develop ways to incentivise and stimulate innovation around the use of data through an evolving ecosystem, including trialling new products and services.

7.3

In January 2020, the Department for Transport has published its Bus Open Data Service with an aim to make it easier to travel by bus in England. The DfT is requiring bus operators to provide open, accurate and up-to-date data (timetable, fares and live location data), creating Public Service Vehicle Open Data regulations enabled by the Bus Services Act (2017), creating new digital services including Publish Bus Data and Find Bus Data, and creating new data standards to address gaps (fares) and mandating existing standards (timetables, location).

7.4

In a Surface Access Integrated Ticketing Report, commissioned by the DfT, commercial barriers have been highlighted as a key challenge by both airlines and surface transport operators for a wider air-rail ticketing uptake. The report also stressed that data sharing is and will be crucial for making integrated ticketing a reality in the UK, but there is currently no public transport data standard for fares and tickets, which poses another barrier to ticket integration.

7.5

Connected Places Catapult (CPC) in their Positioning Rail for the Business Models of the Future paper, released in June 2019, has highlighted two approaches how rail can be an active participant in the MaaS environment: •

•

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A closed ecosystem approach might involve an ‘expanded services’ model, where rail providers would expand their offering to complementary modes of transport (e.g. ‘last mile’ onward journeys) and services, as part of an exclusive end-to-end bundle that is packaged with the train journey.

Open approach would see the rail industry collaborate more closely with third-party service aggregators operating within a digital marketplace. The rail companies would make their data as freely accessible as possible and encourage third-party sales

channels that could evolve to include ticket bundling, end-to-end journeys and, eventually, full integration into a true MaaS ecosystem.

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According to CPC, the second model would lead to greater competition and higher incentives to innovate and require less investment by the rail industry in comparison to the closed approach.

RAILWAY INDUSTRY ASSOCIATION May 2020

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