Consultation outcome

Minimum service levels for passenger rail: government response and policy approach

Updated 6 November 2023

Foreword from the Secretary of State for Transport

The railways have been part of the fabric of our nation for nearly 200 years. They enable millions every day to access vital services like education and healthcare, visit family and provide choice about where to live and work. They contribute to the growth of the economy, transporting goods up and down the country, creating jobs and supporting our ambitions towards a greener future. 

However, recent industrial action across the rail sector has demonstrated that, too often, hardworking people have suffered due to persistent disruption caused by strikes.  

This government recognises the importance, within industrial relations, of the ability of unions to take strike action. And we are committed to ensuring this is protected. But, we are clear that this should not be at the expense of members of the public - who deserve a reliable, consistent service that allows them to work, to learn, and to get on with their lives.  

Time and again, this government has shown that it won’t shirk the long-term decisions to secure a brighter future. When tough choices need to be made, we’ll make them based on the needs and priorities of the British public. So, on industrial action, we’ll not accept the status quo. We’ll strike a fair balance between the ability to strike and the rights and freedoms of the wider public. 

This is why, in February 2023, we launched a consultation on minimum service levels for passenger rail. We wanted to hear the views of the public, trade unions and key stakeholders from the rail sector and beyond. And we wanted to develop a more detailed understanding of the impact of strikes, and how minimum service levels might be applied to reduce disruption.  

This report summarises the responses we received during that consultation and sets out our next steps in bringing forward minimum service levels for passenger rail. We are enormously grateful for the invaluable insight and expertise brought by the public and stakeholders throughout the development of the policy.

The Rt Hon Mark Harper MP, Secretary of State for Transport

Executive summary

Since 2019, there has not been a single day without either a strike happening on the railways or mandates for strikes outstanding. The result has been many periods of disruptive strike action with widespread consequences for those passengers and communities affected.

When a trade union chooses to strike people, including key workers such as doctors, nurses, and teachers, cannot get to work, students cannot get to school and patients’ ability to attend appointments can be affected. While is it right that workers are able to take strike action, it is a priority for the government to protect members of the public from disproportionate impacts of industrial disputes on their ability to make important journeys and on their livelihoods.

That is why the government’s 2019 manifesto committed to ensuring that a minimum level of service can operate during transport strikes. To deliver this commitment, the UK government has introduced the Strikes (Minimum Service Levels) Act (the Act), which became law in July 2023.

MSLs already operate in transport in other countries, such as Italy, Spain, and others. There are a number of different approaches to deploying MSLs for transport that are distinct to the particular country, context, and legal system. The government has developed a specific approach to MSLs in passenger rail that will work for the UK, and sits properly within the UK’s existing legal, industrial relations, and rail operating systems.

The UK government remains committed to supporting employers and unions within the rail sector to address and resolve ongoing disputes, and important progress has been made on live disputes in recent months. Earlier in the year, the Department for Transport (DfT) consulted on proposals to introduce minimum service levels (MSLs) for passenger rail. While the act establishes the mechanism for delivering MSLs across sectors, the minimum level of service for the relevant sector will be set out in regulations. The regulations for passenger rail will be laid before Parliament shortly. These regulations, and the ability for relevant employers to serve work notices established by the act, will ensure that passengers are protected from the harmful impacts of strikes and that they receive a consistent and reliable service on a strike day.

Public consultation

Our public consultation asked for views and evidence in relation to the introduction of MSLs in passenger rail.  It invited views on, and evidence of, the impact on passengers of industrial action, the potential impacts of MSLs including on the rail workforce, the financial and administrative implications of MSLs, and invited views on high-level options for how MSLs might be designed, including their geographic scope. Seventy-eight responses were received to the online consultation, as well as further detailed feedback from organisations such as trade unions, transport operators, local authorities and rail freight operators through a variety of workshops and discussions, and these responses have been analysed and considered by DfT.  

DfT also conducted further analysis using available datasets to model the impacts of recent strikes, the potential impact MSLs could have had during this action, and to consider different ways to design MSLs. This modelling further supported our work to design MSLs to meet our key aims – supporting passengers to make important journeys during strike action (including to get to work, education and healthcare appointments), and limiting the economic impact it can cause.

Further detail on this modelling and consultation responses received can be found in Developing the evidence base and Summary of responses and results.   

Designing a model that works for industry and passengers

A key aim of our consultation was to seek feedback on the different options for designing MSLs for the passenger rail sector. Through the consultation responses and engagement with industry, we looked closely at the impacts of strikes on different parts of the rail network and current industry processes. It was clear that a one-size-fits-all approach for the entire network would not adequately reflect the complexities of the industry, or support us in designing MSLs that are deliverable, and which meet our aims of providing passengers with a consistent service to make important journeys on strike days and to limit the economic damage to businesses and the wider economy of strike action.

In recognition of the stark impacts that different strikes can have on different aspects of the rail network, our approach is to set MSLs for 3 specified passenger rail services that are affected by strikes. These MSLs also work in conjunction with one another where strikes affect multiple different services. These are:

Train operation services

Where a strike affects passenger train operation services, the MSL is the equivalent of 40% of the operator’s timetabled services during the strike.

Infrastructure services (such as the operation of track and signalling)

Where a strike affects infrastructure services that enable the network to be used (for example, strikes affecting Network Rail), the MSL is a list of routes (shown in the priority route map) operating between 6am and 10pm.

Light rail services

Where a strike affects listed light rail systems (trams, undergrounds and metros in Great Britain), the MSL is 40% of that system’s timetabled services for the relevant strike day.

MSLs are a tool for employers, who will be able to issue work notices to trade unions once a strike has been called. The act provides that work notices must identify which employees are required to work to secure the MSLs in the regulations. Employers must consult the trade union on the number of employees reasonably necessary to secure the MSL and deliver the service, and trade unions must take reasonable steps to ensure employees comply with the work notice.

The careful design of these MSLs, based on evidence from consultation and industry, will allow the delivery of a considerable improvement in the service experience by passengers during strikes and limit the economic damage to businesses and the wider economy while providing the industry the flexibility it needs to ensure MSLs are deliverable. MSLs have also been designed with safety in mind and are fully compatible with the industry’s existing safety processes which remain in place as normal when work notices are used.

Next steps

DfT will shortly be presenting the Strikes (Minimum Service Levels: Passenger Railway Services) Regulations 2023 (the Regulations) to Parliament. The Regulations will apply across Great Britain and specify the relevant services in scope and the MSLs for passenger rail. This will enable relevant employers to issue work notices to deliver the MSLs.

This legislation is not intended to prevent the unions from taking industrial action. Instead, this will create a new tool for employers to reduce disproportionate impacts on passengers during strikes.

It will be at the discretion of individual employers whether or not to issue work notices to deliver MSLs. However, subject to the regulations receiving the approval of Parliament, it is our expectation that it will be possible for employers to use MSLs to deliver benefits for passengers from mid-December 2023 in time for the festive period. 

1. Background and objectives

Background

The case for minimum service levels (MSLs) for passenger rail

Our railways are at the heart of our public transport system, and when they are not able to function at full capacity due to industrial action, passengers can face significant disruption to their daily lives and threats to their livelihoods. Coupled with wider negative economic and societal impacts, it is clear the impact of strike activity on the railways can be very challenging for passengers, businesses and the wider economy.

One of the biggest impacts of industrial action on the railway is passengers being unable to get to work, with commuting the most common use of the national railway network in England (38% of journeys in 2022)^{[footnote 1]}. During periods of industrial action, the public has often had to make changes, including working different hours to align with a reduced timetable.

DfT’s survey Rail strikes: understanding the impact on passengers found that 29% of all respondents, and 70% of those who had planned to commute to/from work (by rail) during a strike week, reported at least one impact on their work or working arrangements (including being unable to get to their place of work, having to change their working hours, having to work less than they planned, having to change their working days or being unable to work at all)^{[footnote 2]}. These impacts can be particularly strong when certain groups of workers are striking. For example, during strikes by train drivers this year, the affected train operating companies (TOCs) ran very few services, with some operators unable to run any services at all.

There are also broader consequences resulting from strikes on the railways. In December 2022, the Centre for Economics and Business Research (Cebr) estimated that rail strikes between June 2022 and January 2023 would result in a loss of UK economic output of around £500 million due to people not being able to work. This does not include other economic impacts, such as reductions in spending on retail, hospitality and leisure activities, which suggests that the total economic impact could be considerably higher.

During strike action on the railway, some businesses are unable to operate effectively due to the impact on both employees getting to work and customers/others making journeys. Some sectors of the economy, such as leisure and hospitality, have reported high volumes of cancellations as people can no longer travel and there has been disruption to major public events including sporting events, concerts, and festivals.

This government is committed to taking steps to address these impacts. MSLs will not prevent strike action but will play an important role in ensuring improved consistency for passengers, allowing them to make essential journeys on strike days with more certainty.

The Strikes (Minimum Service Levels) Act 2023

On 10 January 2023, the UK government introduced the act, which brought forward legislation designed to enable MSLs to be introduced across a range of key sectors, including transport. Passenger rail was identified as a priority area for MSLs following the government’s manifesto commitment in 2019.

On 20 July 2023, the act became law. It establishes a clear framework for setting MSLs, recognising the importance of ensuring workers are able to take strike action but balancing this with the needs of the public to get to work and access key services.

The act provides that, for certain sectors, the relevant Secretary of State may specify in regulations the relevant services to which MSLs will apply and what the level will be.

Objectives

The new MSLs legislation is designed to enable people to continue to make journeys by passenger rail while ensuring workers’ ability to take strike action is safeguarded.

Article 11 of the European Convention on Human Rights (ECHR) establishes a qualified right to strike, which means that this should be balanced against the rights of others.

The key aim of the policy is to balance the ability to strike against the rights of people to attend work and education, to receive healthcare and to protect against economic impacts of strike action. This policy does impact the ability of rail workers to take strike action and, as such, DfT has at every stage carefully balanced workers’ ability to take strike action against the needs of people to make important journeys by rail. Ensuring this intervention is proportionate has been an important and ongoing consideration in its formulation.

We envisage the application of MSLs will enable the public to plan their journeys with more confidence and ensure that the timetables that operators will run can be resourced reliably. This will help protect the public and guard against disproportionate impacts on the public, businesses and the economy.

2. Developing the evidence base

To develop the framework for MSLs, DfT first ran a public consultation: presenting the objective that MSLs should be designed to enable people to continue to make important journeys (for example, to access work and healthcare facilities) while balancing the consideration that workers’ ability to take strike action is safeguarded.

The responses were used to inform early drafts of the policy position, with subsequent targeted consultation with stakeholders to develop the policy and test proposals. To further strengthen the evidence base, DfT also conducted its own modelling and analysis on recent industrial action and its impacts, before modelling how that industrial action might have differed had MSLs been applied.  

Public consultation

DfT conducted a 12-week public consultation from February 2023 to May 2023. The consultation covered proposals for implementation of MSLs for both heavy rail and light rail services throughout Great Britain. It also sought to strengthen our evidence base on how heavy and light rail services are used and the impact of strikes.

The consultation built on the evidence from DfT’s analysis of the impact of rail strike action on passengers and included questions on how strikes impact people’s day-to-day lives and their ability to attend work, access key public services and engage in leisure activities such as visiting family and friends or attending events. In addition, we wanted to better understand:

• where people have been impacted by strikes
• what this has meant for them, including:
  • any financial impacts caused by not being able to attend work
  • having to cancel plans
  • decisions to travel in a different way

The consultation also set out our interest in working with industry to understand their experiences of recent strike action, and how the sector has managed the impacts on passengers and workers. It was noted that this operational expertise and evidence would play an important role in informing considerations about what can be achieved through the introduction of MSLs for rail, including any existing good practices that should be factored into the design process.

We invited input from rail workers and trade union members on the expected potential impacts of the legislation, and key considerations on how MSLs for passenger rail might operate.

In addition, we asked businesses (that may not be directly involved in the running of the rail sector, but are impacted by strike action) for their experience. This included considerations such as:

• the impact of employees not being able to attend work
• reduced footfall in certain areas as a result of strikes
• changes to plans such as cancelled bookings due to strike activity

Similarly, we wanted to hear from hospital trusts, schools and other public services that can be impacted during strike action.

Other aspects included which rail services should be in scope of MSLs and what factors should be considered when setting MSLs for rail, for example, route coverage depending on location and time of day. We also wanted to better understand how existing systems, such as the prioritisation strategy that is currently deployed during heavy rail strike activity, could be utilised to inform the design of MSLs.

The consultation sought to test the key principles of how MSLs for rail could be designed. It acknowledged that there are many ways in which we could set MSLs, and explored some options. It also noted that in any approach taken, DfT would weigh key considerations carefully, such as to which aspects of passenger rail services a minimum service should apply and how MSLs could be set.

Two options were proposed in the consultation:

Option 1: design a minimum service level framework based on existing timetable arrangements

This option proposed adjusting the existing timetable to an appropriate MSL which would be set based on evidence from consultation.

Option 2: design a priority route map of the heavy and light rail network across Great Britain upon which minimum levels of service must be provided

This option involved identifying priority lines based on a range of factors including evidence of key routes for high volumes of people getting to work or accessing key services. Two possibilities were suggested:

• option 2a: designing a priority route map focused on increased hours of service
• option 2b: designing a priority route map focused on increased geographical coverage of service

Although no specific levels were proposed for any of these options, views were invited on what the MSLs should be.

The consultation also made clear that we would continue seeking to engage with the devolved administrations and welcome input from operators running services between England, Scotland and Wales, including infrastructure. We also welcomed views and input from mayoral combined authorities (MCAs) and local transport authorities (LTAs) in the context of their transport strategy roles and on how considerations related to those roles interact with the establishment of rail MSLs.

The results of this consultation, and our analysis, are presented in the Summary of responses and results.

Further consultation with stakeholders

In consideration of the responses provided to the consultation, we assessed if there were further evidence gaps and concluded further engagement was required with stakeholders on the implementation of MSLs to ensure as many views and as much information as possible was considered as part of the design of the MSLs and the regulations. This engagement included gathering additional evidence and testing the effectiveness and proportionality of the design of the regulations.

We recognise the importance of ensuring MSLs are implemented in a way that is beneficial for passengers and deliverable by industry, and we were keen to ensure engagement continued throughout the consultation process to capture as much operational expertise as possible. Designing MSLs in such a way as to be operationally viable (such as not to be overly prescriptive) and ensuring that the minimum level of service is appropriate and not more than needed, is a significant challenge given the operational complexity of Britain’s railways.

As part of this further consultation, we sought to engage with the following stakeholder groups through a series of roundtables, workshops and meetings:

• representatives from infrastructure managers, including Network Rail
• TOCs (including open-access operators)
• the regulator – Office of Rail and Road (ORR)
• light rail operators
• devolved administrations
• maintenance providers
• freight operating companies
• trade union representatives
• passenger representative groups

We are grateful to all stakeholders who engaged with DfT during the consultation phase.

The results of this consultation are presented in the Summary of responses and results.

Modelling and analysis

Alongside consulting with stakeholders, we have considered evidence from a variety of sources and conducted further analysis to develop the MSL framework.

To assess the balance of the ability of rail workers to strike with the ability of passengers to make essential journeys, we have considered additional evidence on usage of rail and impacts of strikes in relation to work, education, health, leisure and economic damage. This included assessing evidence from:

• the National Travel Survey (NTS) on usage of rail for different purposes
• data from DfT’s survey on impacts of strikes
• external organisations, such as Cebr, that have published estimates on the impacts of strikes on the economy due to people not being able to get to work

This evidence indicated that rail strikes have resulted in significant impacts on work and the economy.

In developing the proposed approach to delivering MSLs, we have considered evidence on the impacts on workers and the benefits to users associated with geographical coverage, hours of operation, and the overall service level.

To inform the development of the priority route map, we have considered evidence on total usage of different routes and specific evidence on rail use for commuting using MOIRA (a rail industry model, which contains confidential TOC data on timetables, revenue and demand at a rail flow level – mostly station to station flows) and other demand data obtained directly from operators.

We have also considered how availability of alternatives to rail vary by geography, including using data from the Census^{[footnote 3]} and National Travel Survey on car availability and use of different transport modes for commuting. We have mapped routes on the rail network against indicators of rail usage and commuting by rail. We have also considered evidence on the locations of health and education sites in relation to the rail network, which showed a dispersion of these sites across the network and indicated that access to health and education is also likely to be supported by prioritising areas where rail is most used.

To understand the impacts on workers, we have considered evidence provided by stakeholders (from both operators and infrastructure providers) on the staff requirement to deliver the pre-existing strike management strategy and how this might vary if MSLs legislation required greater geographical coverage.

To inform the assessment of hours of operation of the network, we have considered evidence on the pattern of rail usage across the day and usage of transport for different purposes by time of day. We have used this alongside the pattern of services on different types of strike days and on normal (non-strike) days to understand what the impacts on users would be of increasing or decreasing the hours of operation of the network during strikes. We have compared this against evidence provided by stakeholders through the consultation and further engagement on the staffing requirement associated with different hours of service.

To inform the assessment of service levels that heavy rail operators and light rail systems should provide under MSLs, we have assessed data on service levels and wider impacts during past strikes. We have considered evidence provided by operators through the consultation and further engagement on the staff requirement associated with different levels of service for different types of workers, and considered how this compares to the impacts on users of different service levels. We have also considered at what level an MSL would need to be set to deliver benefit to passengers against existing strike arrangements and balanced this against the impact on rail workers, in line with the aims of the policy.

A summary of the results of this analysis is contained in section 3.

3. Summary of responses and results

Having run the public consultation, consulted with stakeholders and completed our own modelling, DfT analysed and considered all the information available as a result. In this section, the results are summarised.

We received 78 responses to the public consultation, comprising 40 responses from individual members of the public and 38 responses received from organisations such as trade unions, transport operators, local authorities and rail freight operators. Not all respondents answered all questions and so, where applicable, the number of respondents who answered each question is noted.

Principles for designing MSLs

Question 1

Respondents were asked whether they agree or disagree with the principles the consultation proposed to underpin MSLs. Respondents to this question comprised 28 individuals and 12 organisations. The 4 principles proposed are as follows:

• that the service that does run during strike action is safe and reliable and allows passengers to travel where possible
• that it prioritises certainty of service, so passengers know what to expect
• that any MSL pays due consideration to safety and security and prioritises passenger safety
• that the needs of passengers and the public to access work and public services are balanced with the ability of rail workers to take strike action

There was broad support for all 4 principles, with the first 3 receiving the highest levels of support. Those who opposed the proposed principles pointed to the impact on workers’ rights and their ability to strike, as well as the need to ensure safety and security for passengers.

Question 2

Respondents were asked to provide feedback on the services that DfT proposed to be within scope for MSLs. Overall, 37 respondents answered the closed portion of this question, 11 from stakeholder organisations and 26 individuals.

Of the list of services provided, the following received the highest levels of support from respondents overall to be within scope, with support outweighing opposition:

• services at stations essential for passenger trains or trams to operate safety and securely
• services provided for keeping track free from obstruction
• services provided by operators of network infrastructure
• services provided by public sector passenger TOCs
• services provided by passenger TOCs in Scotland, Wales and public operators

Services that respondents were less supportive of being in scope were:

• light maintenance services of passenger trains and trams
• services provided by open-access operators

Operators, local and combined authorities, and passenger representative groups were generally supportive of the proposed services list, while trade unions disagreed. Responses from freight operating companies focused more on services that should be out of scope, with the majority wanting to ensure their operations would not be included in setting MSLs.

Operators, operator representatives and businesses also suggested a number of additional services that should be considered within the scope of MSLs. These included services that operate under the Secretary of State for Transport, devolved administrations, infrastructure managers and light maintenance services, emergency repair and operational incident services, station operations and high-speed rail infrastructure necessary for operating international services.

Question 3

Respondents were also asked to consider those services proposed to be excluded from the scope of MSLs. A total of 35 respondents answered the multiple-choice, closed element of this question with the majority agreeing that heritage railways, international passenger rail services and services provided by passenger train operators should be excluded from MSLs. 

It was mentioned by multiple stakeholder respondents that it is important for international services to be out of scope to protect the UK’s relationship with the European Union (EU), because there are alternatives for most users, and to avoid complications regarding international labour agreements.

Question 4

Respondents were given a list of factors proposed to inform MSLs and asked to state whether they agreed with the inclusion of each. Thirty-six respondents answered the multiple-response closed element of this question overall, with 10 being stakeholder organisations and 26 individuals.

Of the factors suggested by the consultation, respondents most agreed with including the need to travel by rail for health purposes or for the purpose of seeking medical attention, and the need to travel by rail to earn a living. Support for including the need to travel by rail to access education, earn livelihoods and avoid damaging the economy was more mixed but broadly supportive. Respondents were less supportive of including the need to travel by rail for leisure or tourism reasons, and the need to travel by rail to enjoy private or family time.

Passenger operating companies and representatives provided mixed feedback on the factors, with broad support but an emphasis on travelling for work. A union respondent disagreed with the factors and expressed concern about the scope of MSLs increasing. Respondents from passenger representative groups highlighted that essential travel for work, education and medical purposes needed to be prioritised.

 Question 5

Respondents were asked to provide feedback regarding the most appropriate metric for setting MSLs. There were 34 responses to the multiple-choice closed element of this question which included 10 stakeholder organisations and 26 individuals. The greatest number of respondents indicated that the percentage of services running compared to a similar non-strike day would be the most appropriate metric (16 respondents). This was followed by those giving other suggestions for metrics (10 respondents).

Gathering evidence to develop MSLs

The next section of the consultation asked questions relating to the following headings: 

• The impacts of rail strike action on rail users
• The impacts of strike action on the rail sector
• The impacts of MSLs legislation on rail workers and organisations representing rail workers
• Projected financial implications of delivering MSLs legislation
• Impacts on employers outside of the rail industry, businesses and organisations representing businesses
• Delivery of rail services on previous strike days

Questions 6 to 11: the impact of strikes on rail users and the rail sector

Respondents were asked to state:

• their experience of travelling by rail and light rail on a regular day
• how far they travel to their usual station (and how far they’d be willing to travel)
• purpose for their travel

They were then asked about their experience of travelling during rail strikes and the impact strikes have had, including types of impacted journeys, increased reliance on other modes and disrupted work patterns and/or personal life.

A range of responses were received. Reasons for using rail and light rail included convenience, frequency and proximity of stations, while purpose for travel included leisure or tourism, work purposes and personal life and family. In terms of distance travelled to their usual station, and willingness to travel to a station, the majority of respondents answered under 4 miles. In terms of respondents’ experiences during rail and light rail strikes, the most common impacts were on respondents’ plans for participation in personal or family life and work-related travel plans.

In response to an open question asking at what point respondents were likely to cancel travel plans on a strike day, responses included:

• when the strike is announced
• a week before the strike is due to take place
• when trains have reduced hours
• when travel becomes more time-consuming
• when there are no viable alternatives to travel
• if services are extremely busy

The representative nature of these responses, in terms of drawing conclusions regarding general rail and light rail travel patterns and the experience of passengers during rail strikes is limited by the number of responses we received. The number of respondents to questions 6 to 11, including related sub-questions, was fewer than 40 and typically between 20 and 30. This resulted in many response categories with fewer than 10 respondents. We have taken this small sample size into account when assessing responses.

Questions 12 and 13: evidence from employers

The next stage in the questionnaire was aimed at employers in the rail sector. The question asked employers in the rail sector to provide evidence on a range of topics. Three responses were received, which provided an insight into each organisation’s operations.

Impacts of MSLs legislation on rail workers and organisations representing rail workers

Question 14

Respondents to the consultation questionnaire were asked about impact of MSLs on rail workers and organisations representing rail workers. Specifically, the question was how they thought MSLs could be set in a way that mitigates strike impacts, while still protecting the needs of passengers.

A total of 7 respondents gave an open-ended comment in response to this question, comprising 1 individual and 6 organisations. Trade unions commented that MSLs would do nothing to resolve current or future disputes, and may make the situation worse. Meanwhile, operators/representatives had several ideas, which included a bespoke MSL for international high-speed rail, and allowing the deployment of a contingency workforce to protect as many services as possible. It was also suggested that there should be a minimum headway set and a list of stations that should remain fully or partially open during the strike. There were also concerns about how the legislation could be enforced without negatively impacting relations with the trade unions and impacting the wider business. 

Operators of light rail commented that core hours should be protected, with these being daytime services and the morning and evening peaks. Those in the local authorities and elected representatives group suggested an MSL of one service per hour on a route. 

A response from a passenger representative group felt that proportionality was important without limiting the ability to take strike action, while it was also necessary to determine what journeys are considered to be ‘essential’. 

Among freight operators, there was generally a concern that when resources are stretched, passenger services are prioritised to the detriment of freight operators, which will over the longer term have a negative impact on the ambitions to grow rail freight, due to perceived reliability issues. MSLs should, therefore, provide capacity for freight alongside passenger services. 

Among businesses and business representatives, there was a view of a need for balance, and that the act, which at the time was passing through Parliament, allows employees to identify individuals who are ‘required to work’ rather than a category of person. This risks that the individual may choose to call in sick and cause service disruption. They also noted that the act does not protect against action short of a full strike, such as overtime bans. A respondent from the aviation sector commented that under MSLs for passenger rail regulations, they would be better able to address uncertainties in services. 

Projected financial implications of delivering MSLs legislation

Question 15

Respondents were asked to provide an assessment of potential costs and benefits of MSLs for passenger rail, including from an implementation and ongoing operation perspective, and propose, where appropriate, ways to offset them without recourse to public funds.

Comments were received from 13 organisations. Trade union respondents suggested that MSLs would increase the power of transport companies at the expense of workers’ rights, prolonging strikes and resulting in lower pay for rail workers. They also argued that an unintended consequence of the MSLs could be in reducing the size of the rail workforce if staff were dismissed for not complying with work notices. They also stated that MSLs might change their industrial action strategy – for example, by taking action short of a strike instead of going on strike.

Among operators, it was considered that additional human resources staff would need to be recruited to deal with the extra administrative work. It was noted that rail timetables are set well in advance of implementation, so the impact of MSLs would be to put extra impact on the rail planning team. 

Freight operators also had a considerable interest in the financial implications of the MSLs. They noted that strikes have resulted in a need for additional resource and adjustment to services – each of which incurs a cost, even with a smaller number of strikes. It was noted that even with the MSLs, network availability would not allow 100% of freight services to operate – therefore, any strikes would result in significant impact on rail freight companies and their customers.

One business representative noted that a complete withdrawal of service has considerable economic impact, leading to greater use of car and air alternatives.

Impacts on employers outside the rail industry and businesses

The next questions were for those employers outside of the rail industry, to determine whether recent rail strikes had resulted in an impact on their business or organisation.

Question 16

Of those that responded to the question about the impact of the strikes on their business or organisation, 11 respondents said that there had been an impact, while 2 reported that there had not.

Respondents were then asked whether the impact on their business related to light rail strikes, heavy rail strikes or all rail strikes. Five respondents said that the impact on their business/organisation related to both heavy and light rail strikes, while 3 further respondents said the impact related to heavy rail strikes only. No respondents said that the impact related solely to light rail strikes. 

Question 17

Having determined which strikes had resulted in an impact on the business or organisation, the next question asked specifically what impact had been experienced. Among the most mentioned impacts on the business were staff absence, loss of revenue and impacts on business viability. Five respondents also mentioned other ways in which their business had been impacted, with these including:

• unrecoverable costs due to missed event bookings (including hotels)
• higher costs
• increased use of road and air alternatives
• an increase in home and hybrid working during strike days

Two further respondent organisations said that the disruption had seriously impacted their ability to deliver freight: finite signalling resource has been prioritised for passenger services, and they argued that, in future, there needs to be a focus on supplying signallers on key freight corridors. Further to this, cancellations had led to goods being delayed and a loss of revenue. Customers have instead used road haulage, especially for time-sensitive deliveries – leading to a broader risk that they will not return to rail in future.

Question 18

To determine further detail on the impact experienced as a result of the strikes, respondents were asked to provide evidence of:

• longer-term impacts, including loss of customers or reputational damage.
• the impact on availability of key workers (for example, emergency services, education, health)

With regard to the first question, 5 respondents (all representing organisations) said that there had been longer-term impacts on their business. This included comments from 2 rail freight operators stating they had experienced the following impacts:

• forcing more people to use road transport increasing congestion and pollution
• loss of business as a potential customer chose to continue using road transport due to the unreliability of the rail network
• long-term reputational damage and the perception that rail freight is unreliable – potentially leading to customers moving to alternative modes and not returning to rail

Respondents representing businesses also commented on the impacts they had experienced, such as:

• inability to facilitate meetings, resulting in reputational issues
• significant impact on the pub and hospitality business, especially in the busy December period – in a sector still struggling to recover from the COVID-19 pandemic and challenges relating to the cost of living

The second part of the question asked about the impact on key workers, to which one response was received. It indicated that the impact on the organisation was limited due to the ability to undertake remote working while some individuals were able to travel on the limited services that operated. 

Question 19

Next, employers responding were asked about any contingency plans they had put in place for rail strike action. Five respondents made comments about their contingency plans. Three respondents from freight operators/associations made similar comments in terms of their contingency plans for strike days, which included:

• more personnel are being trained to develop strike train plans to condense rail freight services into the reduced operating period. This also needs amended working hours and flexibility around various planning departments
• working closely with Network Rail on the development of the Key Route Strategy (KRS) to prioritise services that can run on days impacted by strike action
• working with customers to advance stockpile goods (2 respondents), run to alternative locations and, where needed, make use of HGV transport on days of disruption (2 respondents)

Delivery of rail services on previous strike days

This section considered some factual case studies explaining the levels of service that have been provided on previous strike days and the context surrounding them. Case study A focused on the impact on rail services caused by the National Union of Rail, Maritime and Transport Workers (RMT) strike on 4 January 2023, and case study B focused on the impact on rail services caused by the Associated Society of Locomotive Engineers and Firemen (ASLEF) strike on 1 February 2023.

Question 20

First, the questions dealt with case study A and the experience of travelling on 4 January 2023, with the largest group of respondents responding that they had not planned to travel then and, therefore, did not do so. Meanwhile, 9 respondents had planned to travel by rail but had to change their plans due to the strike. 

Those that answered the question comprised 21 individuals and 8 stakeholder organisations. One further stakeholder organisation (a freight operator) provided a response and commented that some level of service was provided on crucial freight flows, but that some customers saw very few or no services on the strike day. Of the 9 respondents who planned to travel and changed their plans, 6 were individuals and 3 were from stakeholder organisations.

An open-ended element was included in the questionnaire and respondents were asked to explain why they had given the answer they had. The results indicate that the main issue for individuals was that levels of service were too low (not cited by organisations). One organisation said the level of service was adequate, while another said that the route/location was poorly served during the strike action.

Next, respondents were asked about the level of service they experienced during the strike of 4 January 2023 and whether they felt this was too high, too low or acceptable. Seven respondents said that the service was too low on the day of the strike, while a further 2 said the level of service was acceptable, and 2 said they did not know. None of the respondents said that they had felt the level of service was too high. 

Of the 7 respondents who said the level of service was too low, 5 were individuals while 2 represented organisations, with one being a business representative and the other a passenger representative group. 

Question 21

All respondents to the questionnaire were then asked what minimum percentage level of service they would consider acceptable compared to a non-strike day timetable, given there was a strike. The minimum percentage level of service deemed acceptable varied – but the largest group were those in the 0-20% group, who felt that a service provision of 0-20% of normal would be acceptable. However, it should be noted that 6 respondents stated 0%, which means that they deem no service at all to be acceptable on a strike day. 

Table 1:  distribution of responses to question 21

Minimum percentage level of service considered acceptable	Number of respondents
0-20%	11
21-40%	5
41-60%	7
61-80%	2
81-100%	1

As a follow-up question, respondents were asked why they felt the minimum percentage level they had given was appropriate. Those that selected 0-20% commented that workers should be free to strike and that strikes should not happen as the government should resolve these beforehand. A further comment was that peak-hour services around major conurbations should be protected to ensure key workers can travel.

Among those selecting 21-40%, comments included a target of 25%, although on major routes it should be 10%. 

Those that suggested a target between 41-60% included suggestions for a 50% level of service, or more than half so that there is a notable impact, but it is still possible to travel. It was also noted that if the MSL was below 50% users wouldn’t be able to trust the service. There were also suggestions that the service could fluctuate to accommodate peaks, while a further respondent queried what the 50% was expressed as, noting that in their view It should be 50% of normal hours of service (response from a light rail operator).

No comments were left in the 61-80% group, while for the 81-100% group, the sole respondent felt that rail strikes should be illegal due to the disruption they cause. 

A further open-ended question asked respondents to explain what minimum percentage level of service they would consider acceptable given there was a strike. The results indicated that 5 respondents mentioned that the service level should be at least 50% during a strike, comprising 2 stakeholders and 3 individual respondents. 

Question 22

Next, respondents were asked about case study B and their experience of travelling on 1 February 2023. It should be noted that compared to the strike day of 4 January 2023, slightly more respondents planned to travel but changed their plans on the day of the 1 February 2023 strike (11 versus 8 respondents). As for the previous strike day case study, there were 15 respondents who had no plans to travel on the strike day and, therefore, did not do so.

Of the 30 respondents, 22 were individuals and 8 were organisations. Of those who had planned to travel and then changed their plans (11 respondents in total), there were 7 individuals and 4 organisations.

When asked to give details of their own experience of the level of service provided on the strike of 1 February 2023, 6 respondents said that the level of service was too low, while 1 said that it was acceptable. Three respondents said that they did not know while, as was the case for the strike of 4 January 2023, none of the respondents said that the level of service was too high. Of the 6 respondents who said the level of service was too low, 4 were individuals and 2 were organisations.

Question 23

All respondents were asked when compared to a non-strike day timetable, what minimum percentage level of service they would consider acceptable given there was a strike. The minimum percentage level of service deemed acceptable varied, but the largest group were those in the 0-20% group, who felt that a service provision of 0-20% of normal would be acceptable. However, as for the responses relating to the strike on 4 January 2023, it should be noted that 6 respondents stated 0%, which means they deem no service at all to be acceptable on a strike day. 

Table 2:  distribution of responses to question 23

Minimum percentage level of service considered acceptable	Number of respondents
0-20%	10
21-40%	5
41-60%	5
61-80%	2
81-100%	1

When asked to specify why they had suggested the minimum percentage level of service they would consider appropriate, several responses pointed towards previous reasons given. Of those in the 0-20% group, the comments were that workers should be free to strike, that the government should resolve the dispute before the strike and having a peak-hour service around urban areas for key workers.

Of the 21-40% group, a target of 25% was suggested with this being 10% on busier routes, while a respondent described the target of 1 in 4 trains (25%) as realistic.

In the 41-60% group, the comments included a reasonable level of service to avoid crowding on peak trains, and that while their view applied to the network as a whole, it would be likely to be closer to 100% on rural lines.

No comments were made on the 61-80% group or the 81-100% group.

Question 24

The final closed question in this section related to strikes more generally (rather than the 2 case studies), asking about other strike days within the past 12 months and their experience of the services provided on those days. The largest group of respondents said that they felt the level of service was too low (13), followed by those who did not travel on any of the strike days during the last 12 months (10). Three respondents said that they felt the level of service was acceptable, and one said they did not know. As was seen for both the 4 January 2023 and 1 February 2023 case studies, none of the respondents said that they felt the level of service offered was too high. 

As for the 2 case studies, respondents were given the opportunity to explain why they felt the way they did about the level of service offered. The responses given included respondents choosing not to travel, either because they could not reach their destination or because they were able to work from home as an alternative. Some respondents also said that they had cancelled or rearranged their trip, while others were able to make their journey using an alternative mode (such as car or bus).

Options for setting MSLs for passenger rail

The consultation set out 3 options for how MSLs could be designed:

• option 1: design a minimum service level framework based on existing timetable arrangements
• option 2a: design a priority route map of the heavy and light rail network across Great Britain upon which minimum levels of service must be provided – focused on increased hours of service
• option 2b: design a priority route map of the heavy and light rail network across Great Britain upon which minimum levels of service must be provided – focused on increased geographical coverage of service

Question 25

Respondents were asked to indicate their preferred option for MSLs implementation for heavy rail. The preferred option for implementing MSLs on heavy rail was option 1, with 17 respondents giving this response. Eleven respondents preferred option 2, 6 expressed no preference and 1 gave another response.

The consultation also asked respondents about their preferred option for how MSLs are implemented for light rail. The preferred option was also option 1 (13 responses, compared with 4 for option 2), but 13 respondents stated they had no preference and 1 gave another response.

Question 26

Organisation respondents provided additional comments about the 2 options.

Operator/representative, business and transport authority partnership respondents agreed that an MSL based on existing timetable arrangement was preferable as it would result in the highest availability of service given it is already based on customer demand and would be the simplest and easiest option for staff and commuters to understand.

A priority route map was not preferred by operators/representatives for the following reasons:

• requires significantly more evidence-gathering to formulate
• would result in few services overall
• harder to understand for operators and passengers
• would require a new timetable which would require extensive resources
• difficult to draft legislation for
• difficult to apply consistently

Passenger representative groups were mixed in their feedback, weighing the benefits of either option. MSLs based on an existing timetable were seen as beneficial for catering for strikes on different days, and easier planning, especially for passengers who are changing modes or services, whereas a priority route map was seen to better reflect actual levels of demand and essential travel. 

Freight operating companies largely supported a priority route map, as it would provide better capacity for freight operations and that aligning MSLs with the existing timetable would negatively impact key freight flows. It was noted, however, that key freight flows were also contingent on Network Rail staff. 

Two elected representatives provided feedback on the options stating that whole of line service should be the priority. 

None of the trade union respondents identified a preferred option and reiterated their opposition to MSLs. One union stated that, while it did not have a preferred option, it was concerned that the use of MSLs on either option could require a high number of staff to work during strikes and impinge on workers’ rights. It also said that a priority route map impacting heavy rail operators would unfairly impact freight operators and that different rail types need different MSL models applied to their operations. 

Question 27

Respondents were asked to comment on the 2 sub-options for option 2, should MSLs be based on a priority route map. One based on extending hours of service, the other on extending geographic scope of service and whether this preference applies to heavy or light rail.

Option 2b was preferred by more respondents for heavy rail as the most appropriate basis for developing the priority route map, among which there were responses from a light rail operator, a business, a local authority and elected representative, a freight operator and a transport partnership. The freight operator noted that option 2b most closely matched their rationale of providing services on routes where rail is the only available form of public transport.

Option 2a was preferred by more respondents for light rail services, noting that extended hours would appear more useful to passengers than geographical scope of service, as this would better relate to normal origins and destinations. One respondent noted that prioritisation based on extending hours of service was important for those in the hospitality industry who may work outside of normal hours.

Question 28

Respondents were asked to determine from a pre-selected list of options, which factors are the most important in designing a priority route map. Services used by passengers to access school or healthcare were ranked highly by respondents, with 17 respondents giving this first place. Routes that support critical infrastructure and public services also had a high proportion of respondents ranking this in first and second place.

Question 29

In relation to the same proposals for a priority route map, the time periods this would affect were ranked in order of priority. Those time periods with the highest priority were services during a 12-hour period (7am to 7pm) which was an option ranked first by 13 respondents, while the morning peak also ranked highly (ranked first by 9 respondents). Another highly ranked priority was “whatever could be resourced most reliably, regardless of timings” (9 respondents). The later evening option (after 7pm) was ranked lower than the other specified timeframes, being ranked fifth and sixth by over half of the respondents that ranked it.

Question 30

Respondents commented on what level of service they would expect to see on a strike day, as a percentage of the normal non-strike day timetable, following the introduction of MSLs. A total of 20 organisations responded to this question.

All trade union respondents stated there should be no service levels under MSLs as they did not support their implementation. 

Operator/representative respondents agreed that any services provided under MSLs must not be less than the service level that can currently be provided during strike action or the legislation would be ineffective. Flexibility for TOCs to provide the best service for their customers was also highlighted by multiple operators. A service level of at least 60% was suggested by two light rail operators.

All freight operators highlighted the need for service levels that allow their operations to continue on strike days and that freight cannot be overlooked when designing MSLs. It was noted that MSLs need to be dependent on Network Rail providing key signalling and control functions, so should be included.

Question 32

Respondents were asked what the most appropriate factor would be when setting MSLs and were provided with 6 options. Of those, the largest group of responses were for more routes running (9), followed by hours of operation (7). However, 12 respondents indicated ‘other’, and their suggestions included safety (2 respondents), no service at all as workers have the ability to take strike action (3 respondents), and provision of freight rail alongside a passenger MSL.

Further comments included all routes being operated for minimum time periods, having as many routes running as possible (with first, last and peak trains maintained), a factor based entirely on demand. Two final ‘other’ comments stated that you cannot channel preferences in a free society, and that there is no need for MSLs and the government should resolve issues before strikes occur.

Geographic scope

Question 33

Respondents were asked whether they agreed or disagreed that it is important that MSLs apply consistently across England, Wales and Scotland. Most respondents (20 out of 34) agreed with this question. 

Question 34

The consultation asked what the key operational considerations for services between England, Scotland and Wales were. Responses included resourcing crew and stock for the altered service.

A trade union responded that safety was the key consideration, ensuring that staff with appropriate skills are in place and that routes operating have sufficient staff with the appropriate training.

Freight access was also a key consideration in terms of their access to the network and the availability of their required routes. Three freight operators responded, with 2 commenting that key main line rail freight routes need to be open as there are gauge restrictions on some more minor routes as to what can operate. A further freight operator added that should a priority map be used to inform a future MSL for Network Rail, then basing that priority map on the KRS would ensure that the MSLs are able to address any route or regional boundaries.

It was noted that during previous strikes, services in Welsh border areas had been disrupted despite there being no strike in Wales. This was not considered to be sustainable and, therefore, a consistent MSL across all parts of Britain was desirable.

Question 35

The second question asked about what would happen if there were strikes within one part of Great Britain, but not another and how this affects services running between England, Scotland and Wales. Three respondents noted that recent rail strikes had applied across the whole country so there was no experience of such a situation to inform their response. 

A freight operating company commented in their correspondence that as freight services operate nationally, it was crucial that it can operate on the network regardless of how the MSLs legislation is introduced. They considered that the KRS gives a key indication of which routes are required to support critical freight flows and should, therefore, be the basis for a priority route map for MSLs ensuring that they address any regional boundary issues. It was also noted that flexibility in the national timetable would be needed so that it can be re-planned to allow freight services to operate around a region where there are restrictions. 

Question 36

The third question asked about any specific matters relating to Scotland and Wales in relation to the proposals for MSLs. This question was divided into comments regarding matters affecting Wales and comments regarding matters affecting Scotland. 

For Scotland, the main comments made were that there should be a fair service everywhere and that, in areas of similar population density across Great Britain, there should be similar levels of service. One respondent felt that the views of the Scottish Government needed to be taken into account in matters relating to the proposed MSLs.

For Wales, one additional comment mentioned the West of England rail network and its interdependency with the Welsh rail network via the Severn Tunnel – with differences in strike arrangements potentially impacting on services running between the areas. 

Local transport

Questions 37 and 38

Respondents were asked whether they agreed or disagreed that it is important that MSLs apply consistently across MCA, LTA, corporate joint committee (CJC) and regional transport partnership boundaries in England, Scotland and Wales. The largest group of respondents agreed with this statement. 

Respondents through correspondence made comments about local transport considerations for MSLs which included 13 organisations and 5 individuals.

All passenger representative groups who responded agreed with a consistent approach stating that the railways are an integrated transport system, and this would allow for the best customer experience.

Local and combined authority respondents were split in their views with one stating that while consistency between neighbouring local authorities might occur anyway in certain areas, there is also a need to take local requirements into account, such as lack of alternative options. A further combined local and combined authority also disagreed with applying MSLs consistently, noting that services can cover several local authority areas and also that the light rail systems can have different operating modes.  

Summary of further consultation following the public consultation

Following our assessment of evidence gaps in the public consultation, we undertook further engagement with stakeholders to assess operational viability (including safety), deliverability and proportionality to balance our Article 11 ECHR considerations. DfT welcomed the opportunity to speak directly with so many stakeholders, having invited all those listed in Developing the evidence base to meet officials to discuss the proposals, with feedback incorporated into the policy design throughout development.

A summary of this further consultation is outlined below.

Infrastructure operators

Network Rail was consulted throughout policy development, including on the geographic extent and operating hours of the priority route map itself. During previous strike action impacting Network Rail, lines were kept open under the KRS, which is a map of routes that Network Rail considered were both strategically important and were possible to operate using staff who were not on strike (such as managers). They were also keen to highlight the impact on freight in their representations.

We were also able to speak to other infrastructure operators, such as:

• Rail for London, which manages the infrastructure for parts of the London Overground and the Elizabeth Line central operating section
• Transport for Wales (TfW) which, since 2020, has been the infrastructure manager for the core valleys lines as it develops these to become a part of the South Wales Metro

Feedback from other infrastructure operators was similar to that from Network Rail, with a key issue highlighted being the interaction with other operators on shared routes where these infrastructure operators have transitions between their infrastructure and other operators’ infrastructure.

Train operation services and stations

Representations from TOCs focused on the practical challenges currently associated with developing timetables for strike days given the short period between a notice of strike being given and the strike period itself, and the additional complexity that the process of developing a work notice would layer on this.

While we referred operators to the Department of Business and Trade (DBT) stakeholder consultation on its non-statutory guidance on work notices, we carefully considered this interaction when developing these regulations to ensure that the regulations are a usable tool for employers during strike action resulting from industrial disputes.

Operators had a range of opinions on the percentage of services to be chosen, with many highlighting the operational and safety considerations associated with a low percentage, and the proportionality challenges associated with a high percentage given that above a certain percentage of service they would practically require all staff to work to deliver the service.

Train operators were also consulted on the development of the priority route map, given both the interaction of a combined infrastructure and train operator strike, as well as their need to re-plan the train service during an infrastructure-only strike where the priority route map is running. They highlighted concerns around the accessibility of their depots and we were able to include these in the map. They also provided important context to the hours of operation by demonstrating that despite the infrastructure opening at 6am it would not likely be possible that train services would begin running until 7am to allow time to get trains out of depots, and that the reverse occurs at the end of the day.

Recent industrial disputes have involved trade unions calling periods of action short of strike (ASOS) where their members incorporate industrial action into their everyday working, such as:

• through an overtime ban
• refusal to volunteer work on rest days
• refusing to train new colleagues

Train operators were concerned about the interaction of ASOS with MSLs legislation, and whether they could use MSLs to reduce the impact of ASOS on passengers.

During strike action, train operators use contingent staff, such as managers and back-office staff, who take up roles on the railway usually performed by staff who are on strike, to provide a limited service to passengers – this is particularly common at stations. Train operators were keen to explore whether these staff can still be used to supplement the service.

Train operators asked about implications of MSLs on their contractual performance management processes, but given the commercial sensitivity of these arrangements their contacts at DfT will advise individual operators on this.

For those train operators defined as open-access operators, who compete with franchised operators to run services, we were keen to understand the implications of MSLs for them alongside their views on whether they should be in scope. In their representations, these operators confirmed that their experience of industrial action was limited and, as such, they did not feel they would benefit from an MSL, and with limited evidence of historical action, it is hard to demonstrate proportionality.  

Light rail operators

Representations from light rail operators were similar to those of train operators covered above, but with a particular focus on the need to run enough of a service to maintain crowd safety, and their approach given that most are responsible for their own infrastructure.

Freight operators

Freight operators were keen to maintain their access to the rail network during strike action and this was the focus of their representations.

Additionally, there was concern about how a percentage level of service would be set given the dynamic nature of freight flows if a freight MSL were to be developed.

Finally, freight operators were concerned that the use of MSLs by passenger train operators when they are affected by strike action might disrupt freight services if there are short-notice changes to the timetable.

Train maintenance

We understand that around 90% of train maintenance is outsourced by train operators to commercial providers (often the original manufacturer of the trains themselves). From our engagement, we understand train maintenance providers have limited experience of industrial action and that they have sufficient redundancy in their planning to continue to make trains available during short periods of industrial action.

Trade unions

While all relevant trade unions were opposed to the policy on fundamental grounds, DfT was pleased to engage with several trade unions, sighting them on the development of the policy, and welcoming their views on Article 11 implications, contractual relationships between train operators and DfT, feedback on DBT consultations on the reasonable steps code of practice and work notice non-statutory guidance, devolution, the safety of the railway and timelines for delivery.

Devolved administrations

DfT continued to keep devolved administrations updated on progress on the policy, with invitations extended to meetings with the Secretary of State for Transport and ministers updating all devolved transport ministers as part of the regular Intergovernmental Ministerial Group meetings. Officials have met Transport for Wales, Transport Scotland and Scottish Rail Holdings. Extensive engagement has also taken place with all other cross-border operators, such as Avanti West Coast, Cross Country, Great Western Railway (GWR), London North Eastern Railway (LNER) and TransPennine Express.

We appreciate that the devolved administrations may have different views on MSLs, but as industrial relations are reserved and this policy applies across Great Britain, we have worked with industry to understand how MSLs can work for the whole of Great Britain. This is especially applicable to passenger railway services that cross administrative boundaries.

Results of modelling and analysis

Additional evidence has been used alongside the consultation responses to develop the proposed framework.

Analysis of impacts of strikes

Impacts of rail strikes on service levels vary depending on a number of factors including the type of strike, unions and staff groups involved, and employers affected. Over the past year, there have been notable differences in the impacts of national rail strikes depending on whether infrastructure services or train operating services are affected.

Evidence on the impacts of rail strikes on passengers and the wider economy, such as from DfT’s survey on strike impacts, indicates that work and the economy have been most significantly affected. This aligns with work and leisure being the most common purposes of rail use.

Analysis to inform route prioritisation

There is an uneven distribution of services across the network, which means that there is a diminishing marginal benefit in terms of overall service levels as less well-served lines are opened up. Assuming that lines with high numbers of services are prioritised, the additional impact of adding more lines on aggregate service levels is decreasing as less well-used routes are opened up.

Given the increasing staff requirement associated with expanding the geographical scope of the network and the decreasing incremental benefit in terms of impacts on overall service levels, this implies that there should be a degree of route prioritisation whereby not all routes are open during an infrastructure strike.

Mapping of the KRS that Network Rail has operated during recent strikes against indicators of rail usage and commuting by rail has indicated that the KRS has provided good coverage of high usage and key commuting routes. We have also considered evidence on the locations of health and education sites in relation to the rail network, which showed a dispersion of these sites across the network and indicated that access to health and education is also likely to be supported by prioritising areas where rail is used most. To understand impacts on workers, we have considered evidence provided by Network Rail on the staff requirement needed to deliver the KRS and how this might vary if additional routes are added.

Analysis to inform hours of operation

We have considered evidence on the pattern of rail usage across the day and usage of transport for different purposes by time of day. We have used this alongside the pattern of services on different types of strike days and on normal (non-strike) days to understand what the impacts on users would be of increasing or decreasing the hours of operation of the network during strikes. Rail is most heavily used during the peak periods, particularly for commuting, but these peaks have been curtailed during recent strikes affecting Network Rail. It is, therefore, expected that raising the hours of service during strikes would increase the proportion of commuting journeys that are able to take place and also reduce negative economic impacts associated with strikes by facilitating more travel during the evening period.

Increasing the hours of operation of the network will raise the number of staff required to work. Operational workers in the rail sector tend to operate shift patterns, so the number of workers required to work will relate to the number of shifts of workers that are needed. Limiting the hours of service to some extent will, therefore, reduce the number of staff that are required to work.

Analysis to inform service level

Analysis of service levels during past strikes indicates that an MSL of 40% will deliver an increase in service levels compared with recent strikes, particularly those strikes that have resulted in the greatest impacts on service levels. For example, during recent strikes by ASLEF, some operators have been unable to run any services at all (based on Network Rail data on trains run).

However, a 40% service level still represents a significant reduction compared with normal services, meaning that unions would maintain bargaining power through their ability to cause disruption.

The number and proportion of staff required to deliver this level of service are expected to vary by operator and job role, though evidence provided by industry indicates that this service level will allow a substantial proportion of workers to strike on a given strike day.

Analysis of expected impacts of MSLs

We have assessed the likely impacts of the proposed approach. Further detail on analysis and evidence around the expected impacts of this policy will be presented in the impact assessment, which will be published when the regulations are laid.

4. Government response to consultation and policy design

The regulations set out an MSL for 3 categories of service:

Train operation services

Where the MSL is the provision of the train operation services necessary to operate the equivalent of 40% of the operator’s timetabled services (by reference to the National Rail Timetable). This will enable the delivery of a considerable improvement in the service experienced during strikes by staff at train operators and is proportionate in ensuring that staff are still able to take strike action that will have an impact. Aggregate (national) service levels could be higher than 40% because some TOCs may be able to operate higher service levels without using an MSL or because they are not affected by the strike (so are able to operate normal service levels).

Infrastructure services (such as the operation of track and signalling)

Where the MSL is that infrastructure services will be provided during the strike in relation to priority routes (listed in the regulations) but only between 6am and 10pm, including certain infrastructure within a 5-mile radius of the listed priority routes. This defines which parts of the railway network will be enabled to be open during strikes by staff at infrastructure operators (such as Network Rail). See the illustrative map of those priority routes.

Light rail services

This covers 11 specified light rail systems (including trams, undergrounds and metros) in Great Britain. The MSL is to provide the train operation services and infrastructure services necessary to operate the equivalent of 40% of the light rail operators timetabled services relevant to the strike period, giving the operator the flexibility to choose which routes and services to operate to deliver the best possible service for passengers within the 40% scope.

Given broad agreement with the principles proposed in the public consultation, DfT has adopted the principles that the:

• service run under an MSL is safe and reliable and prioritises certainty of service
• needs of passengers and the public to access work and public services are balanced with the ability of rail workers to take strike action

The scope and design of the MSLs have carefully considered the feedback received during the consultation process and seek to achieve proportionality throughout.

MSLs will operate within the rail industries’ existing legislative regime for the provision of services (for example, safety and accessibility systems and frameworks) and the setting of MSLs does not alter the need to comply with these requirements.

Scope of services

The regulations will set out 3 defined categories of services within passenger rail, each with its own MSL.

Train operation services (Category A)

Services for the carriage of passengers by railway (or refuelling of trains) undertaken by TOCs that provide these services:

• under franchise agreements awarded by the Secretary of State or Welsh or Scottish Government
• as an operator of last resort in England, Scotland or Wales
• under operator agreements with a passenger transport executive or local transport authority
• under agreements with Transport for London (or their subsidiaries)

Infrastructure services (Category B)

The following services provided by an infrastructure manager:

(a) reactive maintenance of any part of the network

(b) the exercise of day-to-day control over train movements over or along any track comprised in the network

(c) the operation or reactive maintenance (or both) of a railway signalling system or of any other railway communication equipment

(d) the operation or reactive maintenance (or both) of railway crossings, including level crossings, overbridges, underbridges and tunnels

(e) the control of electrical conductor rails or overhead lines, of any supports for such rails or lines, and of any electrical substations or power connections used or to be used in connection with those rails or lines, and the provision of electrical power by such rails or lines

(f) the provision or operation (or both) of services for the response to, and resolution of incidents on or about the railway including services for the recovery or repair of locomotives or other rolling stock in connection with any accident, malfunction or mechanical or electrical failure

(g) the provision or operation (or both) of services for keeping track free from, or serviceable notwithstanding, obstruction (whether by snow, ice, water, fallen leaves or any other natural or artificial obstacle or hindrance), or for removing any such obstruction

(h) any of the following services for plant, equipment, or machinery used in carrying on any of the activities specified in sub-paragraphs (a) to (g):

     (i) provision

     (ii) operation

     (iii) reactive maintenance

(i) services provided for the purpose of reactive maintenance or stabling (or both) of rolling stock used in carrying on any of the activities specified in sub-paragraphs (a) to (h).

In the infrastructure services set out above, ‘infrastructure manager’ means infrastructure managers of network services as defined in the rail access regulations as well as persons who deliver all those network services on behalf of the infrastructure manager. Category B, therefore, does not include sub-contractors who only deliver some of these services on behalf of the infrastructure manager.

‘Reactive maintenance’ means maintenance that is necessary to ensure the availability, provision or operation of the relevant infrastructure being referred to (such as network or rolling stock). This would not include planned/scheduled maintenance. The construction of infrastructure is also not included in scope.

Light rail services (Category C)

Train operation services and infrastructure services, which have the meaning as for categories A and B, but in relation to the following light rail systems: Blackpool Tramway, Docklands Light Railway, Edinburgh Trams, Glasgow Subway, London Trams, London Underground, Manchester Metrolink, Nottingham Express Transit, Sheffield Supertram, Tyne and Wear Metro, and West Midlands Metro.

Each category is detailed in its own section below. By keeping the categories of services separate, the intent is to make MSLs practical to deliver in most strike scenarios to ensure proportionality and operability of work notices. This means that if a strike is called that only impacts one category of service the MSL only applies to that service.

The regulations apply across Great Britain, where industrial relations are a reserved matter. This decision has been based on feedback received during the public consultation and subsequent engagement that the rail network is not physically segmented by administrative boundaries and, as such, it would not be possible to operate different levels of service in different regions in an operationally viable manner. This is particularly important for cross-border passenger services.

Services not included

We had previously identified in the public consultation that we intended to exclude freight operators, international rail services and heritage rail. Through our policy development and further consultation, we have established that this is the right approach, but have identified that the use of infrastructure services by freight and other operators over the priority routes should continue when these are open anyway for passenger services under MSLs. We have also ensured that connecting lines from priority routes to freight terminals and train depots within a 5-mile radius of the priority routes can be kept open to ensure that freight and other services do not block passenger lines and disrupt service.

We have also decided not to include train maintenance services (other than refuelling by TOCs themselves). Consultation responses and bilaterals, with organisations including Rail Partners and the Railway Industries Association, have indicated that short-term strikes called in recent years have had little impact on the maintenance of trains and indicated that it has been possible to reschedule maintenance services without adverse impacts.

We have also decided not to include open-access operators as they operate a private train service independently of government. Following consultation with these operators, we understand that they have established effective working arrangements with unions in relation to their staff, as reflected by these operators not having a recent history of strike action. For these reasons, we think it would be disproportionate to include open-access operators within the scope of the legislation.

The regulations also do not apply to sub-contractors, other than sub-contractors that are responsible for delivering all the infrastructure services on behalf of the infrastructure manager. This means that where staff are employed by sub-contractors, they are not within scope of MSLs and cannot be named on work notices. We have taken this approach based on feedback from the industry that strikes by sub-contractors are rare and have a more limited impact.

Stations

Station services are not included in the specified services and there is no MSL for these services.

Stations are often operated by one TOC, or the infrastructure operator, but provide services to a number of operators through their regulated station access obligations. There is also huge variation between stations, with some simply comprising a platform with no staff presence and others being larger ‘hubs’, such as Birmingham New Street.

Following consultation with industry, DfT has concluded that it is not possible at present, without further consideration, to develop an MSL for station services that:

• delivers benefits for passengers
• is operationally viable
• is proportionate

This is something that will continue to be monitored.

We understand from operators that they will be able to use contingency staff to operate stations during strike days, as is currently the case. DfT’s priority is ensuring that stations are accessible for both passengers and workers during a strike.

Category A – heavy rail train operation services

The MSL for train operating services is set at 40%.

The MSL for heavy rail train operating services aims to mitigate the impacts of a strike by train operating service staff. The MSL for passenger train operating services is that operators deliver the train operation services necessary to operate the equivalent of 40% of their planned timetable for that period.

This percentage is linked to the public National Rail Timetable for the strike period, being the latest version that applied at the time the employer received the relevant notice of strike action and defined by reference to the journeys in that timetable. This timetable is issued by Network Rail twice yearly.

Responses to our consultation did not lead to a clear overall preference for the MSL. Some respondents indicated a preference for a low service level while others indicated that they would prefer a high service level. We have, therefore, also considered evidence from other sources to inform the decision and the assessment of proportionality.

An MSL of 40% of the number of the operator’s timetabled services during train operation strikes represents an increase in service levels compared with what has been observed during recent strikes, therefore, delivering real benefit to passengers, but would also limit impacts of the policy on workers’ rights and the bargaining power of unions. We think that this service level provides a proportionate balance between benefits for passengers (via increased service levels) and workers’ ability to strike (as service levels increase, that ability is more affected as more workers are required to work).

An MSL of 40% will provide benefits to passengers by raising the number of journeys that are able to take place during peak periods (which would support access to work) than presently operate during strike action. The MSL will also allow more services to operate at other times of the day, which would facilitate other legitimate aims of MSLs including mitigating economic damage and providing access to education and health. The number of passengers who travel in proportion to a normal day of service may well be higher than 40% of the normal number of passengers depending on how TOCs design their timetable and whether individual trains end up more heavily loaded than normal.

However, an MSL of 40% is a considerable reduction in services compared with a ‘typical’ (non-strike) day, indicating that workers and unions would be able to exercise their collective bargaining power to cause some disruption in the rail sector. The impact will be felt by passengers in either not being able to catch their normal train and having to alter plans or having to endure a less comfortable service than normal. Based on data provided by Network Rail, using the number of trains terminating between 7am and 10am and between 4pm and 7pm on a typical non-strike weekday, around 30% to 40% of services operate during the peak periods.

Aggregate (national) service levels could be higher than 40% because some TOCs may be able to operate higher service levels without using an MSL or because they are not affected by the strike (so are able to operate normal service levels).

The train operation services MSL includes all services that a train operator performs to run the service and, as such, will include staff such as train drivers, those who clean the interiors of trains and those who refuel trains, as long as they are directly employed by the train operator.

Category B – heavy rail infrastructure services

The MSL for infrastructure services allows priority routes to be kept open between 6am and 10pm

To set an MSL for heavy rail infrastructure services, we have developed a priority route map that sets the MSL for the heavy rail railway routes in Great Britain (specified light rail systems have their own separate MSL).

The MSL is that infrastructure services will be provided during the strike in relation to listed priority routes but only between 6am and 10pm, including certain infrastructure (such as sidings) within a 5-mile radius of the listed priority routes. This means that a set of routes can be kept open for the specified hours during strikes to enable passenger train services to operate on those lines.

The nature of railway infrastructure operation is such that in terms of staffing levels, rail infrastructure that is open for a proportion of trains (such as 40%) requires a similar number of staff to a railway line that is open to the full capacity of trains. When considering the proportionality of the policy, rail infrastructure/lines are, therefore, considered to be either open or closed. We have chosen, therefore, to prioritise routes by geography and by hours of operation in line with the aims of the policy and to deliver the most benefit to passengers.

The priority route approach is, therefore, a proportionate approach that delivers a simple-to-understand list of rail infrastructure that can be kept open, using work notices, at its full normal capacity.

The list of routes is unique to MSLs and does not confer a different status on those routes or have any link to future investment plans by DfT.

To inform the development of the priority routes, we have considered evidence on total usage of different routes, specific evidence on rail use for commuting, and the availability of alternatives to rail. Mapping of the Key Route Strategy (KRS) that Network Rail has operated during recent strikes against indicators of rail usage and commuting by rail has indicated that the KRS has provided good coverage of high usage and key commuting routes.

We have also considered evidence on the locations of health and education sites in relation to the rail network, which showed a dispersion of these sites across the network and indicated that access to health and education is also likely to be supported by prioritising areas where rail is used most. To understand the impacts on workers, we have considered evidence provided by Network Rail on the staff requirement needed to deliver the KRS and how this might vary if additional routes are added. The priority route map is similar to the KRS, with some adjustments based on our consultation and other evidence on usage of rail.

Use of this MSL should improve the geographical coverage of the network on strike days. We have identified and tested with industry whether there are additional lines that should be prioritised and included. During recent national infrastructure strikes, there have been some high-usage routes that have not operated and have been included in the proposed priority routes as they provide substantial support to the legitimate aims of MSLs. Examples of additional lines that we have included in the proposed priority routes include lines between London and Portsmouth, Bristol and Birmingham, and Glasgow to Ayr.

Hours of operation

The MSL will also only apply between 6am and 10pm. This means if a strike is outside of those hours, the MSL will not apply and cannot be used for infrastructure services at that time.  We have considered evidence on the pattern of rail usage across the day and usage of transport for different purposes by time of day. We have used this alongside the pattern of services on different types of strike days and on normal (non-strike) days to understand what the impacts on users would be of increasing or decreasing the hours of operation of the network during strikes. We have compared this against evidence provided by Network Rail through the consultation and further engagement on the staffing requirement associated with different hours of service.

These hours of operation are longer than the hours of operation in recent infrastructure strikes, delivering real benefit for passengers, but remain proportionate, balancing this with the ability of workers to take strike action. It is anticipated that passengers will most likely experience train services running between 7am and 9pm as the first and last hour of infrastructure availability is generally used by operators to move trains to and from their starting/finishing stations.

The approach to prioritisation of routes and hours of operations seeks to find an appropriate balance in this trade-off that best delivers on the key aims of MSLs by:

• prioritising the routes that are most well-used to maximise the number of passengers that are able to access rail services. Given the increasing staff requirement associated with expanding the geographical scope of the network, and the decreasing incremental benefit in terms of impacts on overall service levels, this implies that there should be a degree of route prioritisation whereby not all routes are open during an infrastructure strike
• raising the hours of operation of the network to ensure that the rail network is open at the times when passengers use it most, to support commuting travel during the evening peak and to reduce economic damage by allowing travel later into the evening

The priority route map is set in the regulations as a list of routes and this list, alongside an illustrative map, is set out in Priority routes. The map is for indicative purposes, with the list of routes in the regulations forming the statutory MSL.

We have taken onboard feedback from freight operators and, where work notices are issued, all operators (including freight) will have access over the priority routes during periods of strike action affecting infrastructure operators while the rest of the infrastructure is closed, although it should be noted that the map has been designed around passenger flows, not freight flows.

Category C – light rail services

The MSL for light rail services is set at 40%

Specified light rail systems in Great Britain, such as trams and subways, will be covered by their own MSL. The MSL will be to deliver the train operation services and infrastructure services necessary to deliver the equivalent of 40% of the timetabled service relevant to the strike period. The timetabled service is the number of trains listed as operating during the strike period in the most recently published timetable by the relevant light rail operator, as of the date of the notice of strike.

Given the differences between the systems, the light rail services employers will determine for themselves how best to approach operating their networks safely at 40% level, and this could mean closing some routes and operating others, or operating fewer services across all routes. Where a system has more than one timetable for its different lines (for example, the London Underground), the 40% will be taken as an aggregate, and the operator will be able to use the work notice mechanism to deliver the equivalent of 40% of the timetabled services across all the lines of the system.

The decision to set the MSL at 40% was made following consultation with stakeholders, who did not indicate a clear preference as to the percentage level. Generally, stakeholders either indicated that a 30% or 50% MSL would be their preference, but that a 40% MSL was deliverable, provided they had the flexibility to determine how this was run throughout the day.

One of the primary stakeholder concerns was the ability to retain flexibility, to ensure that the MSL could be delivered in a way that manages the flow of services and responds to passenger peak times. We have determined that our approach would give the best balance in terms of the benefits to passengers and the impact on the ability to take strike action, noting the concerns in relation to the impact on workers. A separate approach to heavy rail services and MSLs has also been taken, given that light rail systems largely manage their own infrastructure, such that the priority route map, is not applicable.

Priority routes

Indicative map of priority routes

The figure gives an indicative map of the priority route map, where green shows the railway lines included on the map, and all other heavy rail railway lines are shown in grey. This information is also shown in Table 3 below.

Priority route list

Because the list of routes is defined as being between stations, the channel tunnel rail link (which is listed separately in the regulations) does not appear in the list below. This route has been open during previous strikes and will enable international services to use the PRM.

Table 3:  list of priority routes

Origin	Destination	Via	Avoiding
Abbey Wood (ABW)	London Paddington (PAD)
Alexandra Palace (AAP)	London Kings Cross (KGX)
Ashford International (AFK)	London St Pancras International (STP)
Aylesbury (AYS)	London Marylebone (MYB)	High Wycombe (HWY)
Aylesbury Vale Parkway (AVP)	London Marylebone (MYB)	Amersham (AMR)
Balham (BAL)	Sutton (London) (SUO)	Mitcham Junction (MIJ)
Banbury (BAN)	London Marylebone (MYB)	High Wycombe (HWY)
Barking (BKG)	Gospel Oak (GPO)	South Tottenham (STO)
Barking (BKG)	Southend Central (SOC)	Ockenden (OCK)
Basingstoke (BSK)	Reading (RDG)
Bedford (BDM)	Brighton (BTN)	Redhill (RDH), East Croydon (ECR), Norwood Junction (NWD), New Cross Gate (NXG), City Thameslink (CTK), London St Pancras International (STP)
Birkenhead Park (BKP)	Birkenhead Park (BKP)	Moorfields (MRF), Liverpool Central (LVC)
Birkenhead Park (BKP)	New Brighton (NBN)
Birkenhead Park (BKP)	West Kirby (WKI)
Birmingham New Street (BHM)	Crewe (CRE)	Smethwick Rolfe Street (SMR), Wolverhampton (WVH), Stafford (STA)
Birmingham New Street (BHM)	Edinburgh (EDB)	Burton-on-Trent (BUT), Derby (DBY), Sheffield (SHF), Thurnscoe (THC), Wakefield Westgate (WKF), Leeds (LDS), Church Fenton (CHF), Darlington (DAR)	Rotherham Central (RMC)
Birmingham New Street (BHM)	Leicester (LEI)	Nuneaton (NUN)
Birmingham New Street (BHM)	Northampton (NMP)	Coventry (COV)
Blackpool North (BPN)	Manchester Airport (MIA)	Chorley (CRL), Bolton (BON), Manchester Piccadilly (MAN)	Manchester Victoria (MCV)
Bradford Forster Square (BDQ)	Leeds (LDS)
Brighton (BTN)	Hove (HOV)
Brighton (BTN)	London Bridge (LBG)	New Cross Gate (NXG)
Brighton (BTN)	London Victoria (VIC)	Norbury (NRB), Balham (BAL)
Bristol Parkway (BPW)	London Paddington (PAD)	Swindon (Wilts) (SWI)
Bristol Temple Meads (BRI)	Birmingham New Street (BHM)	Yate (YAE), Gloucester (GCR), Worcestershire Parkway (WOP), Bromsgrove (BMV)	University (Birmingham) (UNI)
Bristol Temple Meads (BRI)	Cardiff Central (CDF)	Bristol Parkway (BPW), Severn Tunnel Junction (STJ)
Bristol Temple Meads (BRI)	Exeter St David’s (EXD)	Weston-super-Mare (WSM)
Bristol Temple Meads (BRI)	London Paddington (PAD)	Bath Spa (BTH), Chippenham (CPM)	Melksham (MKM)
Bristol Temple Meads (BRI)	Plymouth (PLY)	Bridgwater (BWT), Tiverton Parkway (TVP), Exeter St David’s (EXD)	Weston-super-Mare (WSM)
Bristol Temple Meads (BRI)	Westbury (WSB)	Bradford-on-Avon (BOA)
Bromsgrove (BMV)	Lichfield Trent Valley (LTV)	University (Birmingham) (UNI), Birmingham New Street (BHM), Aston (AST)
Cambridge (CBG)	London Liverpool Street (LST)	Hackney Downs (HAC), Tottenham Hale (TOM), Broxbourne (BXB)	Stansted Airport (SSD)
Cambridge (CBG)	London St Pancras International (STP)	Stevenage (SVG)	Hertford North (HFN)
Canada Water (ZCW)	Clapham Junction (CLJ)	Clapham High Street (CLP), Peckham Rye (PMR)
Canada Water (ZCW)	Highbury and Islington (HHY)	Whitechapel (ZLW)
Clapham Junction (CLJ)	Stratford (London) (SRA)	West Brompton (WBP), Gospel Oak (GPO)
Cleethorpes (CLE)	Sheffield (SHF)	Mexborough (MEX), Doncaster (DON), Scunthorpe (SCU)	Rotherham Central (RMC)
Cowdenbeath (COW)	Edinburgh (EDB)	Rosyth (ROS), Inverkeithing (INK)
Crewe (CRE)	Manchester Piccadilly (MAN)	Manchester Airport (MIA)
Crewe (CRE)	Manchester Piccadilly (MAN)	Stockport (SPT), Wilmslow (WML)
Crystal Palace (CYP)	Highbury and Islington (HHY)	New Cross Gate (NXG), Canada Water (ZCW)
Darlington (DAR)	Saltburn (SLB)	Teesside Airport (TEA), Middlesbrough (MBR)
Dartford (DFD)	London Bridge (LBG)	New Cross (NWX), Lewisham (LEW), Sidcup (SID)
Dartford (DFD)	London Cannon Street (CST)	New Cross (NWX), Bexleyheath (BXH)
Dartford (DFD)	London Cannon Street (CST)	Abbey Wood (ABW), Greenwich (GNW)
Derby (DBY)	Matlock (MAT)
Derby (DBY)	Nottingham (NOT)	Long Eaton (LGE)	East Midlands Parkway (EMD)
Doncaster (DON)	Leeds (LDS)	Adwick (AWK), Fitzwilliam (FZW), Wakefield Westgate (WKF)
Edinburgh (EDB)	Falkirk Grahamston (FKG)
Edinburgh (EDB)	Glasgow Central (GLC)	Shotts (SHS), Uddingston (UDD), Cambuslang (CBL)
Edinburgh (EDB)	Glasgow Queen Street (GLQ)	Falkirk High (FKK), Lenzie (LNZ)
Edinburgh (EDB)	Helensburgh Central (HLC)	Clydebank (CYK), Glasgow Queen Street (GLQ), Bathgate (BHG)
Edinburgh (EDB)	London Kings Cross (KGX)	Berwick-upon-Tweed (BWK), Durham (DHM), York (YRK), Doncaster (DON), Newark North Gate (NNG), Sandy (SDY), Welwyn Garden City (WGC)
Edinburgh (EDB)	North Berwick (NBW)
Edinburgh (EDB)	Tweedbank (TWB)
Ely (ELY)	London Kings Cross (KGX)	Cambridge (CBG), Welwyn Garden City (WGC)
Enfield Town (ENF)	London Liverpool Street (LST)
Epsom Downs (EPD)	London Bridge (LBG)	West Croydon (WCY), New Cross (NWX)
Falkirk Grahamston (FKG)	Glasgow Queen Street (GLQ)	Cumbernauld (CUB)
Glasgow Central (GLC)	Ayr (AYR)	Paisley Gilmour Street (PYG), Johnstone (Strathclyde) (JHN)
Glasgow Central (GLC)	Gourock (GRK)	Paisley Gilmour Street (PYG)
Glasgow Central (GLC)	Lanark (LNK)	Cambuslang (CBL), Bellshill (BLH), Motherwell (MTH)	Argyle Street (AGS)
Glasgow Central (GLC)	Larkhall (LRH)	Cambuslang (CBL)	Argyle Street (AGS), Motherwell (MTH)
Glasgow Central (GLC)	London Euston (EUS)	Cambuslang (CBL), Motherwell (MTH), Oxenholme Lake District (OXN), Lancaster (LAN), Wigan North Western (WGN), Warrington Bank Quay (WBQ), Crewe (CRE), Stafford (STA), Lichfield Trent Valley (LTV), Rugby (RUG), Milton Keynes Central (MKC), Watford Junction (WFJ)	Argyle Street (AGS), Coventry (COV), Northampton (NMP), Watford High Street (WFH)
Glasgow Central (GLC)	Paisley Canal (PCN)
Glasgow Central (GLC)	Wemyss Bay (WMS)	Paisley Gilmour Street (PYG)
Glasgow Queen Street (GLQ)	Glasgow Queen Street (GLQ)	Bellgrove (BLG), Alexandra Parade (AXP)
Heathrow Terminals 2 & 3 (Rail Station Only) (HXX)	Heathrow Terminal 4 (Rail Station Only) (HAF)
Heathrow Terminal 5 (Rail Station Only) (HWV)	London Paddington (PAD)	Heathrow Terminals 2 & 3 (Rail Station Only) (HXX)
Highbury and Islington (HHY)	West Croydon (WCY)	New Cross Gate (NWG), Canada Water (ZCW)
Henley-on-Thames (HOT)	Twyford (TWY)
Hounslow (HOU)	London Waterloo (WAT)	Kew Bridge (KWB)
Huddersfield (HUD)	Liverpool Lime Street (LIV)	Stalybridge (SYB), Manchester Victoria (MCV), Eccles (Manchester) (ECC), St Helens Junction (SHJ)
Ilkley (ILK)	Leeds (LDS)
Ipswich (IPS)	Felixstowe (FLX)	Westerfield (WFI)
Kettering (KET)	Corby (COR)
Kirkby (Merseyside) (KIR)	Liverpool Central (LVC)
Leamington Spa (LMS)	Kidderminster (KID)	Birmingham Snow Hill (BSW)
Leeds (LDS)	Sheffield (SHF)	Wakefield Westgate (WKF), Thurnscoe (THC), Rotherham Central (RMC)
Leeds (LDS)	Skipton (SKI)	Kirkstall Forge (KLF)
Lichfield Trent Valley (LTV)	Redditch (RDC)	University (Birmingham) (UNI), Birmingham New Street (BHM), Aston (AST)
Liverpool Central (LVC)	Ormskirk (OMS)	Walton (Merseyside) (WAO)
Liverpool Central (LVC)	Southport (SOP)	Waterloo (Merseyside) (WLO)
Liverpool Lime Street (LIV)	Chester (CTR)	Liverpool Central (LVC), Birkenhead Hamilton Square (BKQ)
Liverpool Lime Street (LIV)	Crewe (CRE)	Runcorn (RUN), Acton Bridge (Cheshire) (ACB)
Liverpool Lime Street (LIV)	Manchester Airport (MIA)	St Helens Junction (SHJ), Eccles (Manchester) (ECC), Manchester Oxford Road (MCO), Heald Green (HDG)
London Bridge (LBG)	Sevenoaks (SEV)	Lewisham (LEW), Grove Park (GRP), Orpington (ORP)
London Bridge (LBG)	Tattenham Corner (TAT)	East Croydon (ECR), New Cross Gate (NXG)
London Charing Cross (CHX)	Dover Priory (DVP)	New Cross (NWX), Hither Green (HGR), Orpington (ORP), Tonbridge (TON), Paddock Wood (PDW), Folkestone Central (FKC)	Lewisham (LEW), Bat & Ball (BBL)
London Euston (EUS)	Wolverhampton (WVH)	Northampton (NMP), Rugby (RUG), Coventry (COV)
London Fenchurch Street (FST)	Shoeburyness (SRY)	Basildon (BSO)
London Fenchurch Street (FST)	Southend Central (SOC)	Rainham (Essex) (RNM), Grays (GRY)
London Liverpool Street (LST)	Cheshunt (CHN)	Theobalds Grove (TEO)
London Liverpool Street (LST)	Chingford (CHI)	Walthamstow Central (WHC)
London Liverpool Street (LST)	Norwich (NRW)	Colchester (COL), Diss (DIS)
London Liverpool Street (LST)	Southend Victoria (SOV)	Shenfield (SNF)
London Liverpool Street (LST)	Stansted Airport (SSD)	Tottenham Hale (TOM)
London Marylebone (MYB)	Oxford (OXF)	High Wycombe (HWY), Bicester Village (BIT)
London Paddington (PAD)	Oxford (OXF)	Didcot Parkway (DID)
London St Pancras International (STP)	Nottingham (NOT)	Luton (LUT), Leicester (LEI), Loughborough (LBO)
London Victoria (VIC)	West Croydon (WCY)	Clapham Junction (CLJ), Thornton Heath (TTH)
London Victoria (VIC)	West Croydon (WCY)	Clapham Junction (CLJ), Streatham Hill (SRH), Crystal Palace (CYP), Norwood Junction (NWD)
London Waterloo (WAT)	Dorking (Main) (DKG)	Raynes Park (RAY), Worcester Park (WCP), Epsom (Surrey) (EPS)
London Waterloo (WAT)	Windsor & Eton Riverside (WNR)	Chiswick (CHK), Staines (SNS)
London Waterloo (WAT)	Woking (WOK)	Wimbledon (WIM), Walton-on-Thames (WAL)
Loughborough (LBO)	Sheffield (SHF)	Long Eaton (LGE), Chesterfield (CHD)
Maidenhead (MAI)	Marlow (MLW)
Manchester Piccadilly (MAN)	Reading (RDG)	Stockport (SPT), Stafford (STA), Wolverhampton (WVH), Birmingham New Street (BHM), Coventry (COV), Banbury (BAN), Oxford (OXF)	Didcot Parkway (DID)
Manchester Piccadilly (MAN)	York (YRK)	Fairfield (FRF), Stalybridge (SYB), Huddersfield (HUD)
Milngavie (MLN)	Glasgow Queen Street (GLQ)	Anniesland (ANL)
Moorgate (MOG)	Stevenage (SVG)	Hertford North (HFN)
Newcastle (NCL)	Sunderland (SUN)	Heworth (HEW)
Nottingham (NOT)	Sheffield (SHF)	Alfreton (ALF), Chesterfield (CHD)
New Malden (NEM)	Twickenham (TWI)	Kingston (KNG)
Portsmouth & Southsea (PMS)	Woking (WOK)	Guildford (GLD), Haslemere (HSL)
Rainham (Kent) (RAI)	London St Pancras International (STP)	Gravesend (GRV), London Bridge (LBG)
Richmond (London) (RMD)	Stratford (London) (SRA)	Willesden Junction (WIJ)
Ryde Pier Head (RYP)	Shanklin (SHN)
Slough (SLO)	Windsor & Eton Central (WNC)
Sutton (London) (SUO)	Leatherhead (LHD)	Cheam (CHE), Epsom (Surrey) (EPS)
Stratford (London) (SRA)	Tottenham Hale (TOM)	Lea Bridge (LEB)
Tonbridge (TON)	Tunbridge Wells (TBW)
Uddingston (UDD)	Carluke (CLU)	Bellshill (BLH), Holytown (HLY)
Warrington Bank Quay (WBQ)	Newton-le-Willows (NLW)
Warrington Bank Quay (WBQ)	St Helens Junction (SHJ)
Whitechapel (ZLW)	Stratford (London) (SRA)
Wimbledon (WIM)	Wimbledon Chase (WBO)
Woking (WOK)	Southampton Central (SOU)	Basingstoke (BSK), Winchester (WIN), Southampton Airport Parkway (SOA)

1. 2022 National Travel Survey (2023). NTS0409: Average number of trips (trip rates) by purpose and main mode: England, from 2002. ↩

2. Fieldwork for Rail strikes: Understanding the impact on passengers took place between July and October 2022 in 4 phases. Passengers were intercepted on journeys across the network in the weeks following strike action and asked about the most recent week of strikes. 17,383 passengers completed a questionnaire. This survey does not include Light Rail. ↩

3. ONS (2022) Census 2021: Travel to work, England and Wales, ONS (2013). Census 2011: Method of travel to work, Scotland’s Census 2011: Method of travel to work [accessed June 2023] and ONS (2023) Census 2021: Car or van availability. ↩