National Rail PAYG and Questions About OEPs


With snow dominating much of the transport-related headlines, it is easy to forget that London is now ten days into arguably the largest expansion of the Oyster ticketing system since it first launched. As a result, it is probably worth taking a quick look at what appears to be the situation so far.

A Far-flung Infrastructure

In infrastructure terms, the launch of Oyster PAYG on National Rail appears to have gone relatively smoothly. TfL indicate that overall they were satisfied with the robustness of the system at launch, and that they believe the overwhelming majority of readers were active where required. There were, obviously, failures – units that had either not received required software updates in time or had not been turned on – although these do appear to be in the minority.

To a certain extent, minor issues were always likely to manifest – especially given the relatively lukewarm attitude exhibited by most Train Operating Companies (TOCs) towards Oyster as a whole. What will be interesting to watch, however, will be the level of care and maintenance carried forward – the success of the expansion will depend heavily on ensuring that validators at the more extreme ends of the London rail network are in service for the maximum time possible. Any issues here will likely to become evident over the first quarter of this year.

Asking the Right Questions

One area in which there does still seem to be significant room for improvement is in the information available to travellers and staff knowledge. Whilst the concept of PAYG remains simple, the implementation of it on national rail is not (previous posts explaining it are here and here). Providing accurate information for travellers both on fares and route options is thus vital.

In digital terms, the information provided by TfL is (as is common) largely of a high standard. Similarly most reports so far have indicated that TfL staff have been well briefed on both fares and the system itself. Queries made by LR at a number of Underground and Overground ticket offices (including Liverpool Street, Kings Cross and Hackney Central), for example, resulted in accurate information being passed on with regards to both fares and the need for an Oyster Extension Permit (OEP) on several of the routes queried. What Do they Know currently carries a TfL Staff Briefing Note from the 2nd which correlates closely with the information that was given.

Sadly, when it comes to written information, it appears that the old fares book is now no more – there are a number of “Guides to Oyster” leaflets, however.

At national rail stations, however, staff knowledge of the new system seems to vary greatly. Again, given the lack of enthusiasm exhibited by many TOCs, this is perhaps unsurprising. One major area of confusion appears to be OEPs. Enquiries made by LR at both major ticket offices and smaller ones resulted either in being told “not to worry” about having one for the journey requested (when one was clearly required), or a lack of knowledge that such a thing existed at all. This seems to be in line with the experience reported elsewhere. We have contacted a number of TOCs requesting clarification on the training given to staff before the launch (and going forward), but have yet to receive a reply.

A similar experience seems to exist with regards to OEPs at non-station based Oyster Retailers. LR attempted to place an OEP on an Oyster Card at a number of North London retailers on launch day without success (the request often resulting in a series of blank looks) and again, this seems to have been the experience of others as well. Since launch, returns to the same retailers have resulted in mixed success, with some now able to carry out the action.

As Oyster retailers fall under the remit of TfL, we approached them and enquired as to the level of communication undertaken with retailers. They indicated that the changes to Oyster had been extensively covered in the most recent briefings to retailers and in their monthly updates. They did, however, acknowledge that this did not guarantee that all retailers were fully aware of the changes. They have indicated that if any customers experience problems getting an OEP from a designated retailer, then the customer should contact TfL via the enquiries address, and they will alert TranSys to the need to train that individual retailer directly. [If anyone wishes to do this they can also do so by emailing me, and I’ll pass the details on to TfL myself: – JB]

Fares And Ticketing

In terms of ticket office coverage, there are still plenty of gaps to be filled before PAYG can truly be convenient. Many NR ticket offices are apparently due to begin retailing Oyster from tomorrow, but plenty of gaps will remain. Most notably, South West Trains will not be able to retail Oyster products from their automated ticket machines as they are incompatible with the system (apparently the result of SWT being party to the DfT’s ITSO trials).

Encouragingly, however, it does appear that some of the TOCs are proactively looking for opportunities to extend Oyster options at stations. For example, in response to passenger requests, C2C are now retailing preloaded Oyster cards at Grays, Purfleet, Chafford Hundred and Ockendon as an interim measure until full Oyster facilities can be added.

One thing that the rollout has done, however, is highlight the multitude of fare options now existing in the capital. Travelwatch have warned that travellers should not assume PAYG will always be the cheapest option, Darryl Chamberlain from 853 and Boriswatch have covered various fares issues (and problems for traveling with children) in some detail, which are well worth reading. Whether we see any improvement on this situation in the short term unfortunately seems highly unlikely.

And Thus to OEPs

As can be seen from all the above, it is the issue of OEPs that seems to lie behind the majority of issues so far. This is, of course, far from unexpected.

As more information begins to circulate about the process leading up to the NR PAYG rollout, sources do suggest that TfL argued strongly against their inclusion in the scheme (an argument which was taken to the highest level), but that OEPs were seen as a “dealbreaker” by many at ATOC. Again, this is unsurprising. What is perhaps surprising, however, is that so far the TOCs themselves appear to be showing little interest in enforcing them.

It is obviously worth emphasising that the rollout is at a very early stage and thus the ongoing motives and activities of the TOCs with regards to OEPs can only be speculated at. So far, however, LR understands that at least two TOCs currently have no specific plans in place to enforce OEPs (although this situation may obviously change).

Again, the reasons for this can only be speculated at. From a technical perspective, the collection of fares works fine without them (see Diamond Geezers tests on the 7th of January) so their existence is largely designed to provide revenue protection for the TOCs (as can clearly be inferred from the National Rail Oyster Conditions) and to prevent Travelcard holders from tapping in “in zone,” then failing to tap out “out of zone” to avoid paying a fare.

In a nutshell, therefore, they effectively exist to allow the collection of Penalty Fares. Yet the nature of OEPs themselves seems to raise a number of questions as to how they would fit into a Penalty Fare collection scheme.

The DfT lays down clear guidelines that, in theory at least, a route must conform to before a TOC can carry out Penalty Fare Collection on it. Yet OEPs – at least as it stands – cause issues with all of these.

Passengers must be fully informed before they get on a penalty fares train or enter a compulsory ticket area that they need to buy a ticket or permit to travel before starting their journey, and that they may have to pay a penalty if they do not.

As OEPs are (at least to those not familiar with them) a relative mystery, it is tricky to see how extensive literature and signage would not be required in order to fully satisfy this criteria, as would (importantly) fully informed staff – something that certainly doesn’t seem to be the case as things currently stand.

Passengers must be given a sufficient opportunity to buy a ticket or permit to travel before they get on a penalty fares train or enter a compulsory ticket area.

The key phrase above appears to be “sufficient opportunity” but with OEPs this is something that is likely hard to define. Whilst it is relatively easy to argue that travellers should maintain a decent PAYG balance in anticipation of travel, it is trickier to argue that they should do the same with an OEP. As can be seen above, many national rail stations currently can’t place them on cards, and retailers are not guaranteed to be familiar with them.

Similarly, what constitutes the acceptable distance from a station within which an open Oyster retailer must exist for “sufficient opportunity” to be established in that way?

Also, if an expectation exists that a traveller must maintain an “emergency” OEP as well as a reasonable balance in anticipation of travel then how far ahead should an individual think?

As OEP’s are “one shot” permits, then what happens if two OEP journeys are required within a short amount of time?

None of the above questions are clarified by the new National Rail Oyster Conditions, nor does there seem to have been any major effort to do so. The Oyster Conditions build on the standard Conditions of Carriage, but these also do not provide any guidance with reference to OEP – only the following for electronic ticketing (bolding mine) which would seem to apply to PAYG balance but specifically not permits:

Some Smartcards may be used to buy stored credit which you can use later to buy Electronic Tickets. In these Conditions, credit stored in this way is termed Electronic Funds. It is your responsibility to make sure that you have enough Electronic Funds on your Smartcard to pay for the Electronic Ticket required for the journey you intend to make.

Returning to the DfT’s Penalty Fare policy, therefore, all the above means that its tricky to see how – without further clarification – there could be many grounds on which the absence of an OEP could be used to issue a Penalty Fare or (given the propensity of many revenue offices to “issue first ask questions later”) at least not grant incredibly solid grounds for appeal. Indeed if OEPs were frequently turned over on appeal, then that would also lead to a very strong case for the route (or the OEP-required sections of it) to be removed from being subject to Penalty Fares at all.

Overall, therefore, it would appear that if the TOCs wish to enforce OEP usage then there are certainly a great deal of questions that need to be answered – and answered by the DfT and themselves not by TfL.

If OEPs are more than (as some reports have suggested) a token act of objection to a scheme they disliked but knew was inevitable, then it appears that they will require considerable work (and potentially investment) in order to be rendered a viable means of revenue-protection. Indeed its tricky to see how such an exercise would not, in resource terms, consume more resources than the small and low-level risk they are designed to protect against – especially as most Franchises either already have (or in future will include) smart-ticketing obligations moving forward anyway. It seems unlikely that the TOCs themselves are not aware of this fact as well.

Considering all the above, whilst London Reconnections would certainly not advocate travelling without an OEP, we must admit that we find it tricky to see how the TOCs can currently enforce them, nor how it is likely to be worthwhile their doing so in future.

It’s a question we have raised with the TOCs themselves, and we will certainly be interested to see their answers.

UPDATE: LR also understands that London Travelwatch will call for Oyster Extension Permits to be scrapped in a statement tomorrow, which will express concern at both the complexity of the system, its inconvenience and the potential for passengers to inadvertently find themselves liable for Penalty Fares.

Sharon Grant, TravelWatch’s Chair, is understood to have commented:

The Oyster Extension Permit was a bad idea which is unnecessarily complicated, and it should be dumped as soon as possible.

Thanks to everyone who has emailed in with their Oyster experiences so far, and a special thanks to everyone on for their extensive post-launch research as well.

Written by John Bull
John Bull is the Editor of London Reconnections. A transport journalist and historian, his writing often focuses on the political or strategic challenges facing London's transport network and beyond.