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Consultation Responses Passenger rail services: competition policy project – consultation responses Contents Page Background ................................................................................................................ 4 PART A: Responses to the CMA’s July 2015 consultation on the possibilities for greater competition between train operators in Great Britain’s passenger rail services ............................................................................................................... 5 1. Industry ................................................................................................................ 5 Arriva ............................................................................................................... 5 First Group....................................................................................................... 5 Stagecoach...................................................................................................... 5 Network Rail .................................................................................................... 5 RDG ................................................................................................................ 5 2. Government and regulators ................................................................................. 5 Department for Transport ................................................................................ 5 ORR ................................................................................................................ 5 Transport Scotland .......................................................................................... 6 3. Responses from regional bodies and other groups ............................................. 6 ASLEF ............................................................................................................. 6 Campaign for Better Transport ........................................................................ 6 CILT ................................................................................................................. 6 Mid-Wales Transportation Partnership ............................................................ 6 Newark Business Club .................................................................................... 6 Peninsula Rail Task Force ............................................................................... 6 Powys County Council ..................................................................................... 6 PTEG ............................................................................................................... 6 RMT ................................................................................................................. 6 Scottish Association for Public Transport ........................................................ 7 SEStran ........................................................................................................... 7 Sherborne Transport Action Group .................................................................. 7 Torbay Line Rail Users Group ......................................................................... 7 Transport Focus .............................................................................................. 7 Transport for Greater Manchester ................................................................... 7 Transport for London ....................................................................................... 7 Which? ............................................................................................................ 7 1 4. Responses from international respondees .......................................................... 7 CNMC .............................................................................................................. 7 Regutrain ......................................................................................................... 7 5. Responses from consultants and academics ...................................................... 8 Tony Bolden and Reg Harman ........................................................................ 8 Nick Brooks ................................................................................................... 13 Dr. M J Foster ................................................................................................ 17 Mike Garratt – MDS Transmodal ................................................................... 18 Chris Gidden – CRAG Consultants ............................................................... 18 Tony Lodge – Centre for Policy Studies ........................................................ 19 Professor Chris Nash .................................................................................... 20 Malcolm Pheasy – Nash Pheasy Consulting Ltd ........................................... 20 Michael Schabas – FCP Rail Consultants ..................................................... 24 Jonathan Tyler – Passenger Transport Networks .......................................... 24 Ralph Tiffin .................................................................................................... 48 The Railways Consultancy ............................................................................ 52 6. Responses from private individuals ................................................................... 52 Roger Allen .................................................................................................... 52 Ian Brindley.................................................................................................... 53 David Cooper-Smith ...................................................................................... 54 Allan Dare ...................................................................................................... 55 Peter Foot ...................................................................................................... 60 Chris Fox ....................................................................................................... 64 Stephen Moore .............................................................................................. 70 Stephen Oakley ............................................................................................. 70 John Oliver .................................................................................................... 71 Jukka Rannila ................................................................................................ 75 David Starkie ................................................................................................. 75 David Williams ............................................................................................... 78 Member of the Public 1 .................................................................................. 79 Member of the Public 2 .................................................................................. 79 Member of the Public 3 .................................................................................. 81 PART B: Responses to the ORR’s impact assessment of the CMA’s options for increasing on-rail competition ............................................................................ 82 1. Industry .............................................................................................................. 82 Arriva ............................................................................................................. 82 First Group..................................................................................................... 82 Network Rail .................................................................................................. 82 Stagecoach.................................................................................................... 82 RDG .............................................................................................................. 82 2. Government and regulators ............................................................................... 82 Department for Transport .............................................................................. 82 Transport Scotland ........................................................................................ 82 2 3. Responses from consultants and academics .................................................... 83 Tony Lodge – Centre for Policy Studies ........................................................ 83 David Starkie – Case Associates ................................................................... 83 Ralph Tiffin .................................................................................................... 83 4. Responses from private individuals ................................................................... 88 David Cooper-Smith ...................................................................................... 88 Lorraine Foot ................................................................................................. 89 3 Background 1. On 17 July 2015, the Competition and Markets Authority (CMA) published a consultation document in relation to the possibilities for greater competition between train operators in Great Britain’s passenger rail services. In particular, that document invited responses on the CMA’s four suggested options for possible reform to the system of competition within the passenger rail sector. The CMA set respondents a deadline of 16 October 2015 to make representations. 2. In
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