- We strongly support the “sharing obligation” under FRAND1 terms.
This is the obligation on all railways to make their inventory (all their ticket products) available for resale under fair terms to any ticketing platform that asks for it. This is crucial if passengers want to be able to easily find and purchase the tickets we need for any journey.
- We oppose the “single platform” and “single transaction” requirements.
In the current proposal rights are only available when tickets are purchased in a single transaction on a single platform (ticket seller or reseller). These restrictions in the current proposal are unworkable. Passenger rights must apply to any journey as long as all transfers respect minimum connection times. There will be too many journeys that passengers won’t be able to make with the guarantee and peace of mind of full rights.
- The final legislation should more clearly address how rights will be realised by passengers at the point of disruption.
The experience of passengers should be the guiding principle for making ticketing easier, for the framework under which rights are to be granted, and also for how those rights will be exercised in practice by a stressed traveller stranded on a distant train platform hoping to get to their destination. We need a simple and clear process that, in the case of a missed connection, allows us to get on the next available train without undue burden or hassle.
- FRAND: fair, reasonable, and non-discriminatory↩︎