Regular readers of this blog will recall that four weeks ago we suggested to Translink that the restrictions on carrying bicycles during the morning rush hour should be relaxed to gauge the uptake by commuters on the Bangor-Portadown line.
On October 23, 2023 we filed a Freedom of Information request with the company. This past Tuesday, November 15 we received a response – a week before the deadline. Thank you, Translink!
Having been house-bound this week with the lurgy, I had plenty of time to contemplate Translink’s response and came to the conclusion that what it does not include is as important as what it does contain.
Let me preface this post by highlighting that in their response to Question 1 Translink say, “the disclosure of information under FOI is, legally, disclosure to the world at large […]” so I will copy and paste Translink’s responses here in italics, with my questions in bold and my comments in normal font.
Dear Mr Gloger
Freedom of Information Act 2000 (‘FOIA’)- (Our Reference: FOI1407)
Thank you for your Freedom of Information request of 23 October 2023. Your request is outlined below, alongside our responses:
1. Data on ticket bookings taken on the Bangor to Belfast section detailing occupancy rates/load factor of trains pre- and post-Covid, ideally for each day of the week, split into hourly segments.
We consider that disclosure of the information would be prejudicial to our commercial interests under section 43(2) The Act. To explain this, it is important firstly to point out that the disclosure of information under FOI is, legally, disclosure to the world at large and not just to the individual requesting the information. In that context, disclosure of this information would allow competitors to commercially target peak demand periods by location.
Whilst we always seek to be as open as possible, it is our assessment that the public interest is weighted towards non-disclosure in this case. This is because, although it may be considered more transparent to release the information, the detrimental impact to Translink as a public sector company could be significant and would run contrary to the aim of securing value for money in the public interest.
It is understandable that Translink does not want to publish commercially sensitive information. Unfortunatly that response does not allow us to gauge how much of an impact the carrying of bikes during the morning rush hour might have as we have no idea on when the peak of the morning rush hour occurs and what the load factors are.
However, I did ask explicitly about the time periods during which the information was collected on which Translink’s refusal to change its policy was based (“pre- and post-Covid”). Two possible conclusions could be drawn from Translink not addressing that part of my question:
First, Translink used a boiler-plate response which ignored the time aspect of my FOI request. If that is the case, I would be happy to sign a Confidentiality Agreement and come to Translink’s office to have a look at the data detailing the time periods of the study. I will forward the link to this blog to the Translink General Counsel and Company Secretary with a request for a response.
You may ask, why is this particular bit of information important? It is important for two reasons: first, it cannot be classified as “commercially sensitive” since no granular, commercially sensitive data would be provided, only a couple of date ranges. Second, and more important, it would confirm that data were actually gathered during those periods.
The second possible conclusion is that the lack of specific time references in Translink’s response indicates that no such data collection has taken place.
2. The data set relating to the Bangor-Portadown line used by Translink to formulate the response that “we are not in a position to relax this policy” (no bikes before 9:30am), to include
a. Pre-9:30 passenger (PAX) numbers on the Bangor-Great Victoria Street Station section.
b. 9:30-12:00 PAX numbers (ditto)
c. 16:30-19:00 PAX numbers (Great Victoria Street Station to Bangor)
For the same reasons as are outlined above, this information is exempt from release due to its commercial sensitivity. Suffice to say, NI Railways reviews passenger loadings on all trains twice annually (during March/April and October/November) for one full week. These figures are consistent with normal operations and do not coincide with holiday periods/line closures/periods of extreme weather/major event traffic etc.
Again, the data granularity we requested would allow for determining a rather accurate cut-off point to balance the interests of cyclists with those of foot passengers. Translink’s responses to 1 and 2 do not provide any details on the time frame of the data sets used to arrive at the decision not to amend the time from which bikes are allowed on trains in the morning: were those surveys done before Covid? During Covid? Post-Covid? Were they done at all? The last is unlikely as Translink would have clearly stated if that were the case...
3. One of the trains used on this line (Bangor-Portadown has 6 carriages and therefore capacity for 8 bikes. How frequently does this train run during the morning rush hour (as defined by Translink)? This train has space for bikes in both the first and the last carriage, making it ideal for the trial suggested.
There are two 6-car trains operating out of Bangor each morning (Monday to Friday). These trains depart Bangor at 0851 and 0911 hours. If a trial were to be offered, it would be required across the full network but, in reality, passenger numbers on all lines pre-0930 hours would pose capacity problems. Such a policy could not be adopted on a one-off train.
That sounds like a “computer says NO” response. Where is it written that a trial has to be carried out network-wide? The Cambridge Dictionary defines a trial as “a test, usually over a limited period of time, to discover how effective or suitable something or someone is.”
Using Translink’s logic, the pharmaceutical industry would have to test every new drug on all of Earth’s inhabitants.
Some of the train operating companies have specific restrictions where reservations are compulsory on some services or restrictions are applied to specific services. That seems a good way to handle bikes across a network. Again, like the response to Questions 1 and 2, the absence of concrete data to Quesiton 3 leads one to suspect that no actual survey focussing on the carriage of bicycles was taken.
At least we now know that there are only two trains on the Bangor-Portadown line that are able to take eight bikes. Two trains - out of a total of 17 trains that run from Bangor into Belfast between 0600h and 0930h. That total is made up of 9 “slow” all-stations trains and 8 “fast” trains that take 10 minutes less. The real crux of the problem appears to be that there are not enough long trains available during rush hour.
4. Which “other train operating companies in the UK” were used as the basis for comparison to decide not to change the current policy? The word “most” indicates that there was a number of companies who have different policies. How does their size compare to Translink? That distinction is important because the volume of rush hour passengers on South West Trains and London Underground is much greater than that carried by Heathrow Express or Hull Trains.
Depending on where a passenger is travelling in the UK, different train companies have different rules on bringing bikes aboard. Many require advanced booking of bicycles, and many have time restrictions both in the AM and PM peak. An example of restrictions applied are shown below:-
NI Railways Fold up bicycles permitted on all trains.
Restrictions: Mon – Fri pre 0930 hours in peak directions
Avanti Reservations Compulsory
Great Western Railways Reservations Compulsory – some services
Restrictions: Mon – Fri pre 0945 hours and between 1630 and 1900 hours
Heathrow Express Restrictions: Mon – Fri pre 1000 hours and between 1630
and 1900 hours
Hull Trains Reservations Recommended – first come basis
LNER Reservations Compulsory
London Overground Restrictions: Mon – Fri pre 0930 hours and between 1600
and 1900 hours
Merseyrail Advise to travel in off-peak
Scotrail Reservations Compulsory, reduced numbers before 0930
Southeastern Restrictions: Mon – Fri pre 1000 hours and between 1600 and
Transport for Wales Restrictions: Mon – Fri pre 0930 hours and between 1600
and 1800 hours
C2C Restrictions: Mon – Fri pre 0930 hours and between 1630
and 1830 hours
Chiltern Railways Restrictions: Mon – Fri pre 1000 hours and between 1630
and 1930 hours
CrossCountry Reservations recommended – subject to space
East Midlands Railways Reservations Compulsory – some services
Restrictions on specific services
Gatwick Express Restrictions: Mon – Fri pre 1000 hours and between 1600
and 1900 hours
Greater Anglia & Reservations Compulsory – Some services
Stansted Express Restrictions: Mon – Fri pre 0945 hours and between 1630
and 1830 hours
London NW Railway Restrictions: Mon – Fri pre 1000 hours and between 1600
and 1900 hours
South West Railway Reservations Compulsory – some servies Restrictions:
Mon – Fri pre 1000 hours and between 1645 and 1900 hours
TPE Reservations Compulsory
West Midlands Railway Restrictions: Mon – Fri pre 1000 hours and between
1600 and 1900 hours
That answer is rather useful – thank you, Translink: Someone took the trouble to collate a list of when bicycles can be carried on trains on most UK train operating company (Lumo is not listed, nor is Northern Trains). At least we now have a frame of reference and can construct a Venn diagram with operating companies that are comparable to Translink’s size even though my question “How does their size compare to Translink?” was ignored, probably because of the additional work needed to collate the annual passenger numbers carried by each operator. My question, “[…] there was a number of companies who have different policies. How does their size compare to Translink?” also conveniently was overlooked, probably for the same reason.
Still, we are now able to eyeball that with the cohort data Translink provided. Using a bit of common sense, the following stand out in the list of train operating companies as smaller operators that could be used for a statistically valid comparison with Translink. Their policies on carrying bicycles during rush hour make for very interesting reading:
Hull Trains: Reservations recommended (but not obligatory and no time restrictions)
Merseyrail: Advise to travel off-peak, (but no prohibition to travel during rush hour)
Scotrail: Reservations Compulsory, reduced numbers before 0930 (that’s better than an outright ban)
CrossCountry: Reservations recommended – subject to space (can’t argue with that…)
East Midlands Railways: Reservations Compulsory on some services, Restrictions on specific services (again, that seems reasonable)
TPE (aka TransPennine Express): Reservations Compulsory
Out of 21 UK train operating companies, the six (29%) that allow bicycles before 0930 are comparable in network size to Translink. Two require reservations to take bikes onto trains but the rest manage without. The remaining train companies that do have restrictions mostly service the South East of England with a lot of long-distance commuters who work in London. Long-distance commuting is not prevalent in Northern Ireland.
Should we conclude that Translink refuses to entertain a change to its policy because the company is resistant to change and has not embraced Active Travel? Translink is controlled and supervised by the Northern Ireland Transport Holding Company which is a public corporation and as such “has a duty to operate in line with Ministerial policy” (I'm quoting from its website).
Translink would do well to re-read the Department of Infrastructure’s report The Bicycle Strategy for Northern Ireland: point 5 specifically mentions “support people who choose to travel by bicycle”. Does Translink consider commuters who complete part of their journey by bike second-class “people”, not worthy to be allowed to complete their morning commute using multi-modal transport (bike and train)?
If you are not satisfied with this response you may request a review by writing to the Translink General Counsel and Company Secretary, who has overall responsibility for Freedom of Information and Data Protection issues within this organisation. Correspondence should be addressed to the above-mentioned at: Translink, 22 Great Victoria Street, Belfast BT2 7LX or by email to email@example.com.
If having exhausted the review process you are not content that your request or review has been dealt with correctly, you have a further right of appeal to the Information Commissioner who will make an independent judgement. The address of the Information Commissioner is: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. The address of the Information Commissioner’s Office for Northern Ireland is: 3rd floor, 14 Cromac Place, Gasworks, Belfast, BT7 2JB.
FOI Team – Translink
What we encounter here appears to be an institutional failure on a province-wide scale: the absence of a working Executive allows certain publicly owned corporations to muddle along for years, accountable to nobody while hiding behind studies and data whose existence is questionable. The Climate Change Clock is ticking and in the interim Translink refuses to entertain constructive suggestions to widen the uptake of Active Travel by commuters.
Please comment below what the best way forward is: should we rephrase some of our questions and submit them to the Company Secretary for clarification? Should we continue to work with MLAs who have been in contact with Translink on this issue (and who also have been fobbed off)? Wait until the Executive is working again and then approach the new Minister for Infrastructure? All of the above? Bang our head against the nearest wall?