The UK Govs GBR Consultation – my initial thoughts…

I will cover some of the same content in my presentation to the UK Rail Summit on March 3rd 2025. I will post a PDF of my presentation here.

The GBR Bill was eventually published in early November 2025…I prepared a brief blog with my critique as regards its impact in Wales

On 19th February, 2025, The UK Government (Department for Transport) published its draft consultation, “A Railway for Britain’s Future”. The DfT are…

“seeking views on new policies to be included in the forthcoming Railways Bill, which will enable the establishment of Great British Railways (GBR). GBR will be a single directing mind that will run our rail infrastructure and passenger services in the public interest. The overall aim of these proposed reforms is to provide a railway that works better for both passengers and taxpayers across Great Britain”.

Actual legislation and implementation is expected later this parliament, so organisational changes will likely go live, probably phased, in the period following the end of Control Period 7 in March 2029.

I have opined previously on Williams, Whole industry Strategic Plan(WISP), etc and presented evidence to committees at both Westminster and the Senedd re rail and investment thereof in Wales. I also note that “we” do seem to ask the same questions over and over again as regards the rail industry in the UK. Aside from Williams and WISP we have had in recent years: McNulty (Rail industry efficiency), Laidlaw (WCML franchise failure), Brown (post Laidlaw rail franchising and risk) & Shaw (The Future of Network Rail), and Transport White Papers. Before all that the now archived Eddington Study took a more holistic look at UK Transport and produced a very good report which stressed the economic importance of intra-city/region connectivity. There are probably others.

I have covered some of these in previous blogs, articles and chapters (some of which have appeared in the trade press and other media), for example:

Post CSR, Rail Investment and Wales (updated!) – Mark Barry’s blog site
Welsh Rail Funding – Ministerial Correspondence (December 2024)
The rail industry, Wales & HS2 – and the Barnett Formula (Oct 2024)
What is a Metro? (2024)
Why UK City Regions need Metros (like the South Wales Metro) (Dec 2024)
Cardiff West Junction… (Aug 2024)
GBR – WISP Consultation. My response…(Jan 2022)
The Rail White Paper – some quick reflections… (2021)
Wales and the Williams Review (2019)
Wales’ Rail Network – The Case for Investment – (2018)
Evidence to the Transport Committee Review of HSR in 2011!

The consultation includes a number of welcome “motherhood and apple pie” commitments, which broadly I support. Especially bringing together track/train and removing their commercial “track access charge” (TAC) interface, vesting strategic decision making with GBR and less so the ORR and DfT, and that GBR will be a single directing mind for the network and services…in England(?); although there needs to be much greater English regional influence on that process (see below).

So, for now, I will let others with more expertise and knowledge than me opine on the more generic rail operational issues. I want to focus and make very brief principled comments (re Q17) re how Wales fits into all this and some related points re: funding, integration and the major city regions in England.

As context re the last point, it is worth recalling, that the earlier Labour Government commissioned 2006 Eddington Transport Study found:

“… the strategic economic priorities for long-term transport policy should be growing and congested urban areas and their catchments….”

In this regard, it is very instructive to look at major and comparable cities and city regions in Europe and comparing their public transport provision with the UK. Places like Milan, Marseille, Lyon, Stuttgart, etc all have multi-modal integrated public transport systems with some/all of Heavy Rail (HR), Light Rail(LR), subways, Bus Rapid Transit (BRT), local bus, local tap on/tap off PAYG, etc and all working together via integrated networks, fares, ticketing and information.

In France the government has just expanded its plans for Metropolitan Regional Express Services | SNCF Réseau which will work to create RER Paris style rail based regional public transport backbones in 24 of the country’s city regions. The degree of ambition and especially local, regional and national capability, capacity and alignment are in stark contrast to most of the UK. This Freewheeling blog from Thomas Ableman provides a good overview of the French SERM plans.

This is a key issue for me. The need, especially locally, to integrate rail and bus to create single, seamless, frictionless public transport networks in the UKs major cities and city regions is vital to ensure more balanced and sustainable economic development in the UK. To do so requires a constitutional upgrade and both a functional and cultural change that impacts scale of investment, network/service design and operations, customer information, branding, integrated fares & ticketing, etc.

I would point out, that in Wales this is beginning to happen; TfW has its own brand and is already rolling out capped tap-in/tap-out PAYG on the Core Valley Lines (CVL) and wider South Wales Metro, and that following its One network, one timetable, one ticket policy and under Wales Bus Reform legislation, this capability will be integrated (esp. as regards fares) with, and extended across bus services, some of which like Cardiff Bus already have tap on/ tap off.

The GBR proposal for rail in England does not really consider the bus/rail integration imperative – in fact the word bus only appears twice in the entire GBR consultation document, and bus/rail integration is completely absent (integration is about train and track). As inferred above, in Wales integration between bus and rail is a key policy objective and a priority for Welsh Government and Transport for Wales. Perhaps the DfT is too siloed in its thinking and approach?

Transport planning needs to be localised and better integrated with local bus provision (as TfW are beginning to do in Wales) and land use planning (via new statutory regional bodies in Wales). So, for me, even with the noted role of the regional Mayoral Authorities in England and devolved governments in Wales and Scotland, I am not sure there is enough GBR focus on their role in setting strategy for and integrating local rail with local transport and spatial planning.

Apart from freight and intercity routes therefore, rail planning needs to be more locally integrated across England as we are trying in Wales. For example, the rail industry makes a great play of the ability to buy a ticket between any two points on the network…as if that was of primary importance. In reality it will be far more effective to better integrate local rail and bus services. Most trips are local, and I include car which we need to switch to Public Transport ( PT). Circa 90% of all trips in Wales are intra-regional (and most by car). One can’t just focus on current rail trips; the market opportunity is far bigger! If we are going to decarbonise and in Walers treble the amount of PT(as set out in Net Zero Wales), the target market are not those already using PT – but those still using or having to use (because of lack of alternatives) their cars for too many and especially local trips.

For example, how many people want to travel between say Aberdare and Frodsham by train vs say Aberdare and Talbot Green (which requires both rail and bus)! The former ticket exists….the latter not. This is the primary issue Transport for Wales is dealing with…and will address via Bus Reform.

I am not yet convinced the current UK Government properly recognise the need for major mode shift from car to PT to help deliver our decarbonisation targets. This unavoidably requires more rail capacity (not just electrification) and ultimately road pricing to recover some of the negative externalities of our car dependence (or, as I prefer to call it, the reduction in the “road use discount”). I set out the rationale here The climate emergency and car dependency and How do we make road pricing happen?.

Given the clear differences in approach and much more overt integrated multi-modal remit of Transport for Wales from Welsh Government (WG), it makes no sense to retain a DfT Minster with overall Strategic responsibility for rail in Wales as implied here:

…“The Secretary of State will have a duty to consult Welsh ministers on the long-term strategy.” Whereas in Scotland “Scottish Ministers will continue to set the strategy for the railway in Scotland.

In fact, Wales is more advanced in its mode shift and multi-modal integrated thinking (It already has a Transport Strategy – Llwybr Newydd in place!), so its progress would likely be stymied by retaining London based control/influence. Let’s work collaboratively by all means, but being held back by often disinterested Whitehall decision making has not helped Wales in the past – and many parts of England for that matter. See Why UK City Regions need Metros (like the South Wales Metro).

There are clear needs for common standards and operational alignment in many areas, esp. cross border (which is common between many countries around the world). However, strategic rail planning, powers and funding in Wales needs to be led in and by Wales and integrated with other modes and local planning within its Regional/Metro programmes in each of the regions of Wales. For those still arguing against rail devolution using “but the border” argument, please read: The rail industry, Wales & HS2 – and the Barnett Formula (the constitutional dysfunction) and Background and context for the development of the South Wales Metro (- the biggest devolution mistake?).

The primary issue Wales has faced over the last twenty years has been relative lack of funding by UK Government, especially enhancement, Vs the rest of the UK. A situation now (in Feb 2025) acknowledged at Westminster as set out in a recent series of letters between UK and Welsh Governments. Everything else is secondary to this as an underspend on capital investment in the transport network leads to lower GDP – an issue which impacts all the UK City Regions outside London and something I am covering in my presentation to the UK Rail Summit in March 2025 (Slides here).

As set out, Future rail development in Wales is constrained and limited under the current dysfunctional constitutional arrangements with rail being a non-devolved matter. Although bizarrely, despite not having powers/funding over rail infrastructure, Welsh Government is responsible for the subsidy and operation of TfW rail services. This means WG has no serious capacity to further invest in the capital infrastructure that would result in making its rail services operationally more efficient! (Eg Cardiff West Junction Is a good metaphor for the problem). More stark, when WG does spend capital on rail (as it has done for the impressive CVL transformation in progress as part of the South Wales Metro) it has to fund that from its block grant that does not include any provision for rail, so in effect comes from funding meant for Health, Education, etc

What is proposed for Wales will not address the inequity in rail investment nor will it help the development and thinking re rail strategy and priorities in Wales (See: Future South Wales Metro, Cardiff Crossrail & Metros across Wales ) by having another London based organisation trying to pull at the steering wheel.

I think this also applies to some parts of England which have also been seriously undercapitalised. Even with the nod to devolution, I still don’t see how we deliver equity in investment across the nations and regions under the proposals as set out. There is no mechanism for determining how capital (esp. enhancement investment is apportioned), no reference to the dysfunction of RNEP and so no means to ensure Wales or regions of England gets fairly funded in future. To depend on political pressure and deal making at Whitehall is no basis to build economic infrastructure on this island.

So, in summary and for Wales I think we need:

• Strategic thinking and associated funding and control needs to be devolved in Wales with necessary cross border arrangements and protocols (as is the case in many countries with cross border rail services…which is normal). This means a Welsh HLOS and SoFA under a fully devolved settlement for rail (And adjustment to the block grant, etc).
  
  As a matter of urgency and in advance, Wales needs its own DfT funded “Enhancement pipeline” and an equitable ~5% proportion of the DfT rail enhancement budget (I estimate £80Bn+ over the next 15 years for HS2 completion, Euston, Crewe-Manchester, TransPennine, East West Rail, NPR etc) > PS The Summer 2025 CSR fell some way short!
  
  
• A fair method of dealing with the historic liabilities of the rail network which go back decades, if not centuries and which are a UK Government issue; treatment of liabilities should not be conflated with discussion of where powers and funding over rail enhancement investment reside
  
  
• A much greater focus on the need for rail/bus integration – especially for intra-regional services. On a regional basis this is the most important feature of “good” public transport – and which WG/TfW are trying in Wales (with one hand held behind its back)
  
  
• A much stronger focus, as Eddington set out, on the UKs major city regions and how they are empowered in relation to local economic development and local integration with bus services. There needs to be more overt funding/powers allocated to the city regions in England – command and control won’t work
  
  
• In Wales, WG should lead on policy and TfW on strategic planning, development and operations
  
  
• TfW is and will continue to operate the majority of trains in Wales (as well as fare and ticketing systems); the NR track in Wales (so the Wales Route) should integrate with that – less so GBR. The NR Route in Wales should be an asset management organisation working very closely with and remitted by TfW/WG in Wales (as is the case in Scotland). This arrangement needs to go further than the new successful Cyfuno workstream which I would argue is in part, due to the much more progressive NR leadership in Wales able to work with an empowered TfW
  
  
• On that basis the Wales Route needs to be “pulled out” of the Western Division of NR so it can stand alone within GBR, but much more closely integrated with TfW to reduce the track/train barrier. I also note that having NR present data and stats at the “Wales and West” Division level hides and obscures the situation in Wales vis a vis the Wales Route – and so does not help an informed debate re investment priorities in Wales. Cross border issues (like everywhere else in the world – esp. the rail network in Europe) requires some sophistication and maturity in management arrangements between GBR and TfW
  
  
• GBR is a name too far– just call it BR it’s what everyone knows!

PS I will be covering some of this in my presentation to the UK Rail Summit on 3rd March 2025.

I also touched on some of this in a recent Hiraeth Podcast from 47:20