Derogations - allowing uncompliant stock still to be used in 2020

[whole diary]

[grahame]

Just a sample - expect to see quite a bit more of this stuff ... this for Heathrow Express units class 332 from the DfT^» (Department for Transport - about)

Dispensation - Description
4.2.2.12.1 - Platform step/gap
4.2.2.8.3 para 1 - Bodyside passenger information displays
4.2.2.3 para 10 - Width of wheelchair backstops
4.2.2.6.3.1 paras 6 & 7 - Minimum clearance space inside the toilet compartment
4.2.2.6.3.2 paras 1, 2 & 3 - Baby change facility

[Celestial]

I thought the Heathrow Express stock was all due to be withdrawn by December to enable the depot to be demolished for HS2^▸ (The next High Speed line(s)).  Maybe this suggests that schedule is running behind?

[IndustryInsider]

There’s going to be a bit of an overlap but I doubt Class 332s will be in use much beyond next spring.

[bradshaw]

Richard Clinnick of Rail Magazine on Twitter today

With the decision by @GWRHelp to retain the 8xCl.143s into next year, it means all three TOCs^▸ (Train Operating Company) with #Pacers will continue with them in use beyond the planned Dec 31 2019 withdrawal date. GWR^▸ (Great Western Railway)'s plan is the same as @northernassist in that a DDA^» (Disability Discrimination Act - about)-compliant 15x will run with the 14x. 

@Clinnick1

[johnneyw]

Can anybody help me answer a question I was asked as to when the last Pacer was used on the Severn Beach Line?

[grahame]

Can anybody help me answer a question I was asked as to when the last Pacer was used on the Severn Beach Line?

According to WikiPedia

Until 2012, Class 143 Pacer units were a regular sight, but these were moved south to work in Devon following a cascade of Class 150/1 units from London Midland and London Overground

They may have made irregular appearances since - I have seen reports of the odd one reaching Bristol within the last couple of years, though not out onto The Beach.

[johnneyw]

Thanks Grahame, my guess was that the last one I saw gracing the Severn Riviera Express was more than half a decade back and I don't recall any being roped in to cover for early Turbo unreliability (it was probably impractical by then) but I wouldn't fall of my chaise longue to learn that some still ran after 2012.

[grahame]

From the highl technical start to this thread, we move on to the way derogations are described in mainstream press

From The Guardian

Train firms backtrack over pledge to ban raw sewage on railway line

A pledge to end the dumping of human waste on railway tracks in England and Wales by the end of the year will no longer be met, Network Rail and train firms have admitted.

Although Network Rail’s former chief executive, Mark Carne, said in 2017 he had secured government agreement to end the “disgusting practice” by 2019, several companies will continue to use trains whose toilets flush directly onto the track.

In 2017 the Department for Transport had said all franchises would compel firms to ensure trains had modern toilets, but several operators have now applied for exemptions. Labour said it was “totally unacceptable that railway workers continue to endure such unsanitary conditions in the 21st century”.

East Midlands Railway, whose contract was awarded to Abellio only this year, may not phase out some offending rolling stock until 2023, it has emerged. It has been given permission to continue dumping sewage on the track from fast trains running between London St Pancras to cities including Nottingham and Sheffield.

A spokesperson said most trains were already fitted with tanks and others were being removed or retrofitted. He added: “We completely support the drive by Network Rail to remove all trains without controlled emissions toilets by the end of 2023 and are already working towards having all our trains operating with tanks by the end of 2020.”

Others still believed to be operating trains that dump excrement on tracks include Northern, West Midlands, ScotRail and Transport for Wales. A West Midlands spokesperson said that non-compliant toilets on older carriages would be locked and out of use from the end of the year.

ScotRail said it was fitting retention tanks to its high-speed InterCity trains during a refurbishment programme “as soon as possible”. Transport for Wales said it was investing in new trains, phasing out the last offending rolling stock by 2023.

Article continues ...

So derogations until 2023.  Hardly a surprise that the end-of-year (2019) targets are being missed. Noting that the blame is being laid on the doorstep of many including those TOCs^▸ (Train Operating Company) who are very new to their franchises, how fair or otherwise is it to blame those companies.  Did they come in knowing they would have a problem and be allowed a derogation?

[eightonedee]

Just a sample - expect to see quite a bit more of this stuff ... this for Heathrow Express units class 332 from the DfT^» (Department for Transport - about)

Quote
Dispensation - Description
4.2.2.12.1 - Platform step/gap
4.2.2.8.3 para 1 - Bodyside passenger information displays
4.2.2.3 para 10 - Width of wheelchair backstops
4.2.2.6.3.1 paras 6 & 7 - Minimum clearance space inside the toilet compartment
4.2.2.6.3.2 paras 1, 2 & 3 - Baby change facility

Reflecting on this, it perhaps shows how there is a gap between those who prescribe what should be provided and the passengers who use trains.

Putting on one side catering facilities on trains that travel more than a specified distance or undertake journeys of more than a specified time (off you go Broadgage!) are any of the following covered?-

Maximum and minimum volume of on train announcements

On board electronic signage that works reliably and automatically, linked to a system (eg GPS) which can track where the train is an pick up obvious problems (such as a recent case where internal signs on an IET^▸ (Intercity Express Train) to Oxford insisted that it was stopping at Theale and Thatcham and the next station was Theale all the way from Reading to Goring)

On board WiFi that does not require daily commuters to sign in every time they change trains (including filling in all my personal details usually in the case of the system on Electrostars)

Carpet materials that clean easily and don't show dirt.

Tip up seats for use by able bodied passengers in disabled/wheelchair spaces when not required for such use

No seats which do not have full window views

Somewhere by each seat to rest drinks container/book/laptop etc

Minimum reliability standards for air cooling/conditioning and adequate emergency window opening when they breakdown.

Minimum standards of hand washing and drying facilities in toilets

Minimum number and size of rubbish bins, and standards of distance from each seat and door/vestibule

No more than 4 seats across

Arm rests capable of being raised where fitted to ease access/egress from seats

First class signage that is disabled/removed when the stock operates on services that are standard class only

Minimum standards (design/dimensions) for cycle storage  - current provision does not seem to work, possibly also provision for storage for folding bikes too.

Door release buttons on both sides of the doors

Communications systems between drivers/train managers and signallers/control to enable instant provision of delay/problem information to passengers on board (no more "We are at a red signal, unfortunately I have not been told when we might move, but I hope to hear in the next 10 minutes and I'll let you know when I have any more information")

 
I'm certain other forum members can add to this list!

[Rhydgaled]

Just a sample - expect to see quite a bit more of this stuff ... this for Heathrow Express units class 332 from the DfT^» (Department for Transport - about)

Quote
Dispensation - Description
4.2.2.12.1 - Platform step/gap
4.2.2.8.3 para 1 - Bodyside passenger information displays
4.2.2.3 para 10 - Width of wheelchair backstops
4.2.2.6.3.1 paras 6 & 7 - Minimum clearance space inside the toilet compartment
4.2.2.6.3.2 paras 1, 2 & 3 - Baby change facility

Reflecting on this, it perhaps shows how there is a gap between those who prescribe what should be provided and the passengers who use trains.

Putting on one side catering facilities on trains that travel more than a specified distance or undertake journeys of more than a specified time (off you go Broadgage!) are any of the following covered?-

There is a document, the Key Train Requirements (PDF file), KTR for short, that covers some of the issues you mention. At some point 'ownership' of the document passed to the Rail Delivery Group, but I don't think following the 'requirements' it contains has ever been mandatory.

Here are some examples of where the document makes recomendations in line with the issues you listed.

• Carpet materials that clean easily and don't show dirt. Carpets should not require abrasive chemical and processes to clean them.Deep pile carpets are not suitable as they tend to hold on to dirt.
• Tip up seats for use by able bodied passengers in disabled/wheelchair spaces when not required for such use Occasional-use seating should be provided in multi-use areas (D).This could include tip-up and perch seats. Not sure if wheelchair spaces count as 'multi-use areas'.
• No seats which do not have full window views I'm not sure 'full' window views at every seat is possible on modern trains due to the width of the solid pillars between the windows, but the KTR document says The rolling  stock design  should  ensure  that  all  passenger  seats  are  aligned  to provide a view through the adjacent window
• No more than 4 seats across Purposely excluded from the KTR due as a business decision, however the study into seat comfort included minimum seat widths and it was recommended that the findings from that be incorporated in a later edition of the KTR. That might (depending on what the minimum seat width is) be a death-sentance for 2+3 seating, but only if the standard is made mandatory
• Arm rests capable of being raised where fitted to ease access/egress from seats Where provided, armrests should be moveable and of a length and height designed to accommodate a majority of the population

 

I'm certain other forum members can add to this list!

I would probably add several, but for now just this one number of toilets fitted, to which the KTR says provision of toilets should be based on the following minimum ratio of seats to toilets (D):➢For intercity or inter-urban services, 85 seats per toilet,➢For short distance / commuter services, 125 seats per toilet and All multiple units shall have a minimum of two toilets provided (B).To avoid major problems in the event of one toilet becoming defective. Of course, Northern and Transport for Wales have ignored this with just the one (fully-accessible of course) toilet proposed for their new 2-car CAF Civity units (and, in Northern's case, even on the 3-car and 4-car units I believe).

[eightonedee]

Thanks Rhygaled - most interesting.

A couple of questions for any forum members who might have the information-

1 - Were the IETs^▸ (Intercity Express Train) ordered and specified before requirement of seats to align with windows sufficient to provide a view?

2 - How could CAF/their commissioning ROSCOs^» (Rolling Stock Owning Company - about) and the franchise operators "get away" with specifying fewer toilets than the requirements? I'm not sure that a derogation for this (if granted) is more acceptable than allowing stock without disabled access toilets, or lack of retention tanks for a further year or two. These are after all new stock that will be with us for the next 30-40 years. 

[Rhydgaled]

Thanks Rhygaled - most interesting.

A couple of questions for any forum members who might have the information-

1 - Were the IETs^▸ (Intercity Express Train) ordered and specified before requirement of seats to align with windows sufficient to provide a view?

2 - How could CAF/their commissioning ROSCOs^» (Rolling Stock Owning Company - about) and the franchise operators "get away" with specifying fewer toilets than the requirements? I'm not sure that a derogation for this (if granted) is more acceptable than allowing stock without disabled access toilets, or lack of retention tanks for a further year or two. These are after all new stock that will be with us for the next 30-40 years.

The first issue of the document was in Jan 2011 according to the amendment record section of the second edition (Feb 2013), so possibly too late to impact on the IEP^▸ (Intercity Express Program / Project.) specification. Window alignment was covered in the 2013 version at least (I don't have a copy of the 2011 version).

The CAF fleets can be explained by the 'requirements' contained in the document not being mandatory. Even then the 'requirements' are broken down into 'essential requirements', 'desirable requirements' and 'depends on a business case decision'.

It is more a voluntary 'best practice' type document than anything else. The window pillars on the class 195s are also thicker than the maximum recomended in the KTR as far as I could tell with a tape measure. It also specifies that couplers should be Dellner  12  /  Voith  136 / Faiveley  130  or  equivalent,at  a nominal 925 mm Above Rail Level, presumably to ensure trains can be coupled to any other unit, but this seems to be ignored as well (and unlike the toilet one the couplers are labeled as an 'essential requirement', at least in the latest version which specifies different couplers than the 2013 version which had an option for BSI^▸ (British Standards Institute) couplers).

[eightonedee]

Thanks for that further information.

This looks like a matter that might usefully be subject to consultation with passengers and passenger groups. Re-reading extracts, I would think many (most?) passengers might not agree with the classification of some of these items, and others as "E" and "D" in particular.

[stuving]

Thanks for that further information.

This looks like a matter that might usefully be subject to consultation with passengers and passenger groups. Re-reading extracts, I would think many (most?) passengers might not agree with the classification of some of these items, and others as "E" and "D" in particular.

If you look in any "how to design stuff" textbook, or course on engineering design practice, it will tell you that specifiers of systems used by the public should include them as "users" in conjunction with themselves (the commercial customers). That means going out and consulting them about what they want - but almost certainly not by one of those formal consultation exercises. They would look for "real" users, not people who respond to public consultations!

However, this rarely happens as effectively as senior management claim it does. The railway world is as full as the rest of it with people who know their customers ... they just know they do!

But to return to the point of digression:

Reflecting on this, it perhaps shows how there is a gap between those who prescribe what should be provided and the passengers who use trains.

"Prescription" applies to PRM^▸ (Persons with Reduced Mobility)/accessibility (the topic up to then), and I expect most of us think that should be dealt with by regulations and laws. The general view is that the government (DfT^» (Department for Transport - about)) has got involved too much with running the railway, or micromanaging it, and ought to be pushed back out (by Williams or something). So it looks a bit odd to be asking for general train design and passenger preferences to turned into official regulations.

[grahame]

Chris Heaton-Harris, the Secretary of State at the Department for Transport, has written a strong letter to Paul Plummer, Chief Executive, Rail Delivery Group on Compliance with rail accessibility requirements for 1 January 2020:

It is extremely disappointing that the rail industry and train operators will fail to meet the deadline to provide accessible trains for every passenger and every journey by the end of the year.

I have mirrored the full text of the letter {{here}}

Stephen Brookes MBE, BA^» (British Airways - about)(hons) - Rail Sector Champion for the Cabinet Office Disability Hub and Minister for Disabled People - has copied the letter widely and backed it up with the words "Disabled people and organisations will be observing the process with keen and watchful interest.".

Personal view - there is little doubt in the general disappointment at the need for the derogations, but I do wonder if the failure to meet the deadline - with the continued travel difficulties it will bring accessible travel to all in 2020 - is really all the fault of the rail industry (operators and suppliers).  Should not the government take some share of the responsibility for failing to provide a setup / system under which the deadline they set could be reached?