Firstly , the ORR have stated that "no closure references have yet been submitted for our consideration."

ATOC RESPONSE TO NETWORK RAIL’S BUSINESS PLANNING CRITERIA AND BUSINESS PLAN (link below.)
http://www.rail-reg.gov.uk/upload/pdf/nrbp2005-atoc.pdf

Key passage :

"Network Rail’s 2005 10-year Business Plan

We welcome the publication of Network Rail’s Business Plan, which is an essential document for all train operators. In particular, the route analysis is important.

However, we have some concerns about the assumptions within the business plan and also the level of analysis that is provided.

We are concerned especially that passenger train miles are assumed to grow by just 2% by 2007/08, after which no growth at all in passenger train miles is assumed. This contrasts with assumed freight train tonne miles growth of almost 24% by 2014.

This low growth in passenger train miles does not reflect our overall expectations for passenger growth over the next ten years (although some of this will, of course, be accommodated on longer and more heavily-loaded trains), especially in some parts of the network that are already very crowded. The new RUS programme will go some way towards identifying passenger demand from the bottom up, but a more realistic national assumption must also be adopted. We would be pleased to work with both the ORR and Network Rail to determine this.

We also have some concerns about the improvements in efficiency that Network Rail assumes: for example, while there are large strides forward in reducing maintenance costs in the first four years of the plan (to 2008/9), maintenance costs after this point decline only marginally. This may be due to reaching the point of optimum expenditure, for the outputs that are achieved; but it is important that Network Rail demonstrates how it has determined that it will have reached this point of maximum cost-efficiency."