The DfT data room has all the data any bidder requires including sales and earnings data, so innovation in bids is not affected by the current status if data. In addition al, TOCs can see ORCATS allocations through Lennon. They can agree with other service providers their own sakes allocations of sales. ORCATS is not specified in the TSA, it says allocations should be done by surveys,but until the format of surveys is agreed ORCATS should prevail. It is a very sophisticated model. Originally devised to support allocation of BR costs to revenue holders by service code more than 30 years ago. ORCATS evolved and changed under BR, but very few changes since 1996. It's strength is partly incumbency, partly because alternatives are considered to costly and the impact on revenue unknown. Only Travelcard for the inboundary elements have used survey and real usage data (PAYG). Maybe widespread use of gates and validators, with digital ticketing, will lead to the retirement of ORCATS.