ACE slams rail regulator for "ridiculous" CP6 consultation timeframe

The Association for Consultancy and Engineering (ACE) has hit out at rail regulator, the Office of Rail and Road (ORR), for the “ridiculous” three-week consultation period given for the Network Rail’s five-year £47.9bn strategic plan to improve Britain’s railways.

Managed by the ORR, the consultation, published last month, asks for feedback on nearly 1,800 pages published by Network Rail for CP6 (which runs from 2019 to 2024), yet only provides 14 working days to respond. This amounts to over 130 pages a day, or £3.42bn of the plans’ proposed rail investment, per day of the consultation.

ACE has pointed out that the government’s own principles on consultation, last updated in 2016, state that they should “last for a proportionate amount of time” and “facilitate scrutiny”. They also state that, “consulting too quickly will not give enough time for consideration and will reduce the quality of the responses”. 

"To say we're disappointed not to be able to properly scrutinise the £47.9bn strategic plan is an understatement. We should have had three months, not three weeks to respond. The timeframe provided for a document of this size was ridiculous."
Nelson Ogunshakin, chief executive of ACE.

Commenting on the consultation time length, chief executive of ACE, Nelson Ogunshakin, said: “That we’re disappointed not to be able to properly scrutinise the £47.9bn five-year strategic plan, is an understatement. This consultation is of huge importance to the future of our rail network and will impact on millions of passenger journeys every day. This isn’t the way to engage stakeholders, nor to produce robust and properly thought-through plans. We should have had three months, not three weeks to respond. The timeframe provided was for a document of this significance, ridiculous.” 

Despite the short timeframe, ACE has still provided feedback on Network Rail’s summary of CP6 strategic business plans, as well as “deep-dives” on two areas of the consultation - Network Rail’s infrastructure projects division and the Anglia route.

ACE believes that Network Rail’s infrastructure projects division (IP), which oversees major infrastructure projects, should:

• Think of passengers as the ultimate external stakeholder, resulting in a more customer-focused approach;
• Reduce the amount charged based on the proposed headcount reduction which will significantly lower overheads;
• Look beyond the rail sector and strive to be better than similar organisations abroad and in other sectors; and
• Go into greater detail and share the lessons learned from CP5 for CP6, allowing for stakeholders to feedback.

A spokesperson for the ORR, said: "The current consultation is part of our extensive two and half year engagement programme ahead of CP6 starting next year. We required Network Rail to engage with its stakeholders as part of the development of its plans. These plans have now been submitted to us for our review and we invited high level feedback from stakeholders to inform our assessment. We will consult on our proposed decisions in June, which will give stakeholders a further opportunity to comment."

Of the £48bn total initially allocated to Network Rail in October by the government, the strategic plan details £47bn of spending split between previously agreed enhancement projects, renewals and operations and maintenance, with the final £1bn saved for some smaller infrastructure projects. A total of £10bn will be allocated to ensuring ongoing projects are completed.

The business plan published by the rail operator has been described by its chief executive Mark Carne, as “ambitious but realistic” and would “deliver a better railway that Britain needs”. However, it has been criticised by some in the industry for the lack of new major projects announced, with a noticeable emphasis placed on general improvements when compared to previous control period spending.

Network Rail says it will attempt to slash train delays by 15% and provide 1,000 extra services by 2021 through the targeted spending.