Rail Users Ireland, on behalf of the rail passengers of Ireland and also as members of the European Passenger Federation on behalf of those EU citizens who visit Ireland and travel by train, wishes to object in the strongest manner possible to the request recently submitted by Iarnrod Eireann to withdrawn service between Waterford - Rosslare.
Irish Rail has failed to engage with stakeholders in the area and state in general as to the future of the line and has proceeded without first obtaining the necessary approval of the NTA before publicly committing to closure. Irish Rail has selectively chosen to engage with two railway preservation organisations but not even to notify any parties or organisations such as Rail Users Ireland who support the continued operation of scheduled daily services.
We submit that Irish Rail has made no meaningful effort has been made to reduce costs, and that Irish Rail has in-fact deliberately constructed a scenario to undermine the routes performance.
- The signal cabin at Wellington Bridge could be switched out without impacting on the current timetable
- The single coach railcars purchased specifically to operate the service are rarely used inflating the running costs
- Irish Rail has constructed a complex and inefficient rostering arrangement despite train crew being based at both ends of the route
- No marketing effort has been made to promote the route
- No information concerning fares on the route is published on Irish Rail's website or at any station on the route
- The Rosslare line mini-ctc signaling has a unique quirk that Rosslare Strand signal cabin need only be staffed for Waterford line services, no staff are needed for Dublin line services
We submit that Irish Rail has willingly and knowingly conspired to undermine the viability of the route. Transport Act 1958 sec 19 "(2) The Board shall not terminate a service unless it is satisfied that its operation is uneconomic and that there is no prospect of its continued operation being economic within a reasonable period."
We submit given the statements above that Irish Rail cannot close the line as no effort has been made to address obvious issues and to obtain cost savings which do not impact on the passenger experience.
Irish Rail has been negligent in its operation of the service
- Breaches of the Irish Rail customer charter - failure to provide up to date timetabling information at stations thus discouraging use
- Failure to implement the mandatory portions of EC 1371/2007 with respect to pre journey information at unstaffed stations. This is denied by Irish Rail in correspondence. Rail Users Ireland intends to take action to require legal enforcement of this regulation on Irish Rail
Bus Alternative Cannot Match Service Offering Of Train
We submit that the bus alternative put forward fails in several key ways to be a reasonable alternative and replacement of the train by a bus would lead to a reduction in accessibility and thus leave Irish Rail in breech of the commitments given to satisfy the requirements of the Disability Act 2005.
- The bus alternative is not accessible while the train is
- Rail offers the quickest possible journey to Waterford - any road based alternative must travel via New Ross adding 30 minutes to the journey
- The train carries bikes, bus alternative is unlikely to important given ferry connection at Rosslare
- Bus option is heavily limited in capacity while the rail option can adapt as required
Feasibility of putting a bus service in place
- Any bus alternative must be subject to open competitive tender through the OJEC this will take several months
- Obtaining a bus license is a long process and based on experiences of others, e.g. Patton Flyer in Dublin many years may pass without resolution.
- Any bus service will require a subsidy which must be budgeted for and approved by the Department of Transport. It has been clearly indicated that no such funds are available.
Taking these factors into account, we request that the NTA using the powers granted to it, refuse Irish Rail/CIE permission to withdraw services and to take the following steps.
- Require Irish Rail to complete following within 3 months
- Provide signage, timetables and information at all stations to meet the commitments given in the Irish Rail customer charter and under EC1371/2007
- Alter the evening departure time from Waterford to 17:40
- Irish Rail to reintroduce the connection to Wexford in the evenings
- Revised and expanded timetables such that through services from Galway to Rosslare exist to minimise changes and reduce journey times
- Implement a performance regime in line with best practice. The current NTA contract makes no reference to the performance standards on this route.
- Clear notice when engineering works are taking place - it is very rare for notice to be given of works on the Limerick - Rosslare line
- Clear advertisements in local radio and print media as to the timetable, fares and also the ferry connections available and the fares for such service
While Irish Rail has put forward a plan to convert the line to a preserved line such would mandate a significant extension in journey times. Regardless such a project is ambitious, costly and has no confirmed backing and is likely to fail when faced with the complex safety requirements. It will not serve the interests of the current passengers.
Follow Up Submission Following Section 19 Notice by CIE May 21
We find that the proposed alternative from Irish Rail is in conflict with Clause 3.4 which appears in both Bus Eireann's and Irish Rail's NTA contracts.
"The Operator shall, in so far as possible, and, in any event, without discrimination integrate all Services provided by it with those of other public passenger transport services including by participating and complying with integration measures introduced by the Authority under Chapter 3 of Part 3 of the Act of 2008."
In the notice published pursuant to Article 19 of the Transport Act 1958, none of the replacement services offered will serve Waterford train station. This does not satisfy the need to provide multimodal integration.
No alternative services are offered from either Waterford train station or from Ballycullane and that all alternative services offered take longer than the current rail services.
We therefore request again that the NTA refuse Irish Rail permission to withdraw the rail service and to instead to implement the measures laid out in our initial submission.