A single across-the-board structure for train fares based on kilometres travelled could see a Wollongong-Sydney trip cost as much as $22.
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At present, train fares are calculated via five different distance bands with relative prices becoming cheaper the further someone travels.
For instance, someone taking a 10-kilometre train ride would pay a fare equivalent to 35 cents a kilometre, while a Wollongong-Sydney commute costs just 13 cents a kilometre.
If the 35-cent rate was charged across the board, it would mean a $22.75 fare between Wollongong and Sydney - and that's one way.
Independent Pricing and Regulatory Tribunal (IPART) is undertaking a review of the fares and has raised questions about the fairness of those travelling longer distances paying less.
"It can be more equitable to charge more for travelling longer distances in that it means all users pay a similar price per kilometre travelled, and those who only ever travel short distances do not pay more as a result of the government's decision to provide more expensive longer distance services," an IPART paper on Opal fares stated.
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"However, it can also be less equitable if those required to pay higher fares for longer distance journeys are predominantly people on lower incomes."
IPART has flagged it is considering adjusting prices for longer trips versus shorter ones, stating the former have fallen 60 per cent in real terms over the last decade.
"If long distance fares are relatively low, either the taxpayer subsidy required to pay for these services needs to be higher or passengers travelling shorter distances need to pay more," the paper stated.
"Either way, the result of spending more money to provide lower fares for passengers who travel longer distances is that there is less money available to spend on other parts of the public transport network than there would otherwise be."
IPART will make its recommendation on fares to government early next year.
"IPART is responsible for setting a maximum fare however the final decision on any fare belongs to the government," said a Transport for NSW spokeswoman.