The rules around the accessibility of trains to disabled people change as of the start of 2020. By this time, the entire UK rail fleet must be accessible, as set out in the Rail Vehicle Accessibility (Non Interoperable Rail System) Regulations 2010 and the technical specification for interoperability in respect of persons with reduced mobility. The latter is an EU policy, but don’t be distracted by Brexit – it will be brought wholly into UK law by the European Union Withdrawal Bill when it is passed and becomes the European Union Withdrawal Act.
This is good news, and not before time.
Except there’s a problem. And wouldn’t you know it, that problem occurs on the Midland Main Line. As things stand, once we get into 2020, the Midland Main Line will not have enough compliant trains for its services.
One of the respects in which trains must be compliant with the new regulations relates to their doors, and how people get on and off the train: manual slam-doors are not compliant, as very obviously if you’re in a wheelchair or on crutches you’re going to find them very difficult and potentially impossible to use.
The iconic Intercity 125, more commonly referred to a a High Sped Train (HST) which makes up part of the fleet used by East Midlands Trains (EMT), features slam doors. Or more accurately, the British Rail Mark 3 coaches that are used in HSTs have slam doors. The other part of the EMT fleet, the newer class 222 ‘Meridian’ diesel units, have powered doors and are compliant (as does the entire Thameslink fleet, and basically all reasonably modern trains). Modifying the older trains by the end of 2019 will not be possible.
So, how have we ended up in this mess, and what’s the way out? As with everything going wrong on the Midland Main Line, it’s at last partly due to the decisions made to delay and then scrap the electrification scheme…
What went wrong
In 2012, the Department for Transport’s High Level Output Specification for Network Rail’s Control Period 5 (CP5) set out the now notorious raft of ambitious electrification schemes that includes the whole of the Midland Main Line. This pledged that electrification would reach northwards to Nottingham by December 2019, and Sheffield by December 2020, as well as to Corby (starting at Bedford – the section between Bedford and London has been electrified since the early 1980s, and part of the Thameslink network since 1988).
At that time, the franchise held by EMT was due to expire in 2015, and so it would be for the new franchise to order the new electric trains to run on the line. Bringing in these new trains would automatically bring compliance with the disability regulations (as they apply automatically to new trains as they are built).
However, both those plans – for the franchise, and for the electrification – changed. In 2015, Network Rail paused its electrification programme as it became clear that it had been far too ambitious: not only could the available pool of engineering expertise and hardware not electrify so many routes in such a short space of time, but the costs of electrification had been massively underestimated. On the Great Western Main Line, where work had at least got underway, costs were overshooting budgets at an eye-watering rate. Sir Peter Hendy, who instigated the ‘pause’ shortly after becoming Chairman of Network Rail, has gone on record to say it would have challenged the Government’s demands for CP5 if he had been in charge at the time. Eventually, the Secretary of State, Chris Grayling, decided to bin electrification of the Midland Main Line altogether – with the exception of the stretch from Bedford north to Kettering, and the spur from Kettering to Corby.
Meanwhile, EMT’s franchise was extended to March 2018, then to March 2019; it seems likely to be prolonged to August 2019 (a separate article will follow on the franchising shenanigans…). This left the operator in place until just before the deadline for the disability regulations, but no plans or requirements for ordering new rolling stock now that the line would not be electrified. Grayling made clear he expected new bi-mode trains (capable of using electric power when running under wires, and diesel engines when not) in place under the new franchise – but there is no requirement on East Midlands Trains to introduce them under its current franchise.
Obviously, entire new fleets of trains can’t be procured, built and introduced in the few months between the new franchise starting in August or March 2019 and the disability regulations coming into force at the start of 2020. So you’d have thought that either EMT might take responsibility for sorting out the problem, or that the Department for Transport (DfT) would spot that actually there was no obligation on EMT to do any such thing, and step in. Neither of those things has happened. There’s another party involved too: Porterbrook, which actually owns the HSTs and leases them to EMT – because that’s how our privatised railway system was set up in the mid-1990s. Porterbrook stated in 2015, when asked, that it was evaluating its options with regard to HSTs and the fact they might be needed beyond 2019 now that electrification was ‘paused’. But nothing happened.
Where does that leave us? Well, East Midlands Trains currently runs 27 Meridians (compliant, no problem), and 11 HSTs (with a twelfth on loan to LNER, formerly Virgin Trains East Coast, which is expected to come back to EMT by the end of 2018). All of these trains are capable of running at 125mph, although the Meridians have faster acceleration and therefore can be used to run slightly quicker services. EMT therefore needs either to make its HSTs compliant with the regulations, or replace them with other trains capable of delivering the same level of performance.
So, is it possible to modify the Mark 3 coaches in HSTs to make them compliant? Yes, it is. Chiltern services operating out of Marylebone have been using Mark 3s with sliding ‘plug’ doors for some time. Some of the HSTs displaced by the new electric trains on the Great Western route are being fitted with compliant doors, either to run in Scotland or to run on local routes in the West Country. Cross Country is also modifying its HSTs to be compliant. And there’s the problem: there’s a lot of demand for work to modify Mark 3 coaches. In fact, all the available space in the supply chain is booked up. There’s no way of modifying extra coaches for the Midland Main Line by the end of 2019. If Porterbrook / EMT / DfT had taken action in 2015, they could have placed the order for the work – the modifications for the HSTs due to work in Scotland were known about, but the work on the Great Western and Cross Country sets hadn’t been ordered, so the supply chain was not yet bunged up. But nothing happened. According to Porterbrook, the best that could be achieved now would be to complete the work by 2021/22, just as the new bi-mode trains are supposed to come into service anyway, and at a cost of £50 million or more.
Possible ways out
Spoiler: there is no way out.
But a lot of energy has been expended looking for one.
Firstly, could other trains be brought in to replace the HSTs – or more accurately, the Mark 3 coaches? No, they couldn’t: there are in fact very few types of diesel train that are capable of running at 125mph in the UK, and there certainly aren’t 11 whole trains that will be available. One wonders whether some of the modified coaches due to be used in Scotland or the West Country might be borrowed by EMT, leaving Scotrail and GWR to make do with their existing trains for a couple more years. But this won’t happen – those operators have signed contracts to lease the trains, made promises to their passengers about improved services, and also agreed to cascade their old trains to other routes or operators. So forget that.
There has been a lot of speculation about using British Rail Mark 4 coaches instead, propelled by the existing HST power cars. These coaches are currently used on the East Coast Main Line, and are a more modern (well, 1980s) design with compliant electric doors. Sounds great, right? Unfortunately, there are problems. Firstly, they are heavier than Mark 3s: seven Mark 4s is equivalent to eight Mark 3s (the current length of nine of EMT’s sets, the others being six coaches long), so the trains wouldn’t be able to run to the same timetable – they would take longer to accelerate. Reportedly the engine manufacturer MAN has offered to uprate the engines in the power cars to allow for that; and there are options such as switching off some of the on-board electricals for short periods when the train needs maximum power to accelerate. But none of that is the biggest problem with using Mark 4s.
A much more fundamental technical issue with Mark 4s is that they do not use the same type of supply for the on-board electricals: the Mark 4s have a 1000V single phase system, whereas the Mark 3s have a 440V three phase, variable frequency system; more practically, the Mark 3s have three cables down the side of the coaches; the Mark 4s have two, running round the train to complete a conventional circuit (and no, you can’t just use two of the three on the Mark 3s). This is not insurmountable, technically: a traction converter has been developed that could in theory be used (currently fitted to the class 73 locomotives that are used on the Caledonian Sleeper). But the complexities of asset ownership in the railways come in here: the Mark 4 coaches are owned by the leasing company Eversholt, whereas the power units of the HSTs are owned by Porterbrook, and in six cases Angel Trains (I was simplifying it a bit previously, believe it or not). So, who pays for the work? And where is the device fitted – in the coaches, or the power units? It’s a mess, and frankly all a bit fanciful. But none of that is the biggest problem with using Mark 4s.
The biggest problems with using Mark 4s is that they won’t fit. Literally. They’re too big for the line. Gareth Dennis unpicks this issue extremely pithily in Rail 850 (April 11 2018). The key concept here is gauging envelopes: how wide or tall can a carriage or locomotive be without striking objects near the track – bridges, signals, platforms and so on? Platforms are particularly important – necessarily, they are close to the track so that people can get on and off the trains! This picture is made more complicated by the fact that trains move. At speed they might sway slightly from side to side, but also when they go round curves, think about how they behave: the ends of the coach move ‘out’, away from the curve, while the middle of the coach moves ‘in’, close to the inside of the curve – the coach stays straight, of course, even if the track it is on is curving. See the photo below of a metro train in Chicago taking a tight corner – the straight edge of the carriage is clearly overhanging the inside of the curve of the track; if there was a platform there, the train would obviously strike it (and not coincidentally, the platform in the foreground is on a straight section of the track).
So, here are two key facts: Mark 4s are fatter at the ‘step’ (the portion below the level of the platform) than Mark 3s; and the Midland Main Line has a lot more curved platforms than the East Coast Main Line, where Mark 4s are currently used without problems. Take those two things together, and basically the Mark 4s won’t fit. Gareth Dennis estimates the work necessary to modify platform edges to accommodate Mark 4s on the southern part of the route alone would cost £2 million. Ian Walmsley estimates the traction conversion work, fanciful though it might seem, would cost another £2 million. It’s a lot cheaper than the cost of modifying the doors on the carriages. But will the money be found, and all the work completed, by the end of 2019 – just 18 months from now? Forget it.
The only way out
There are only two options to solve this mess. One is for the HSTs to be withdrawn at the end of 2019 and EMT to be left to operate its service with far too few trains. Given the appalling screw-ups we are seeing on the railways at the moment, I don’t entirely discount this as a possibility. But far more likely, and the only practically feasible solution is for the Secretary of State to issue a derogation from the regulations, and allow the Mark 3s to continue in service. Bad news for disabled people, but the only way to keep the service running at all.
This brings us to the recent role of ministers in addressing this problem. A recurring theme on this blog will no doubt be a lack of a ‘controlling mind’ for the railways, and a corresponding lack of accountability. It is a system with many moving parts: the DfT, Network Rail, the train operating companies, the rolling stock leasing companies… And this allows the DfT, and ministers in particular, to intervene or wash their hands of a situation as suits them.
At times they are extraordinarily interventionist: the DfT procured and mandated the use of the new fleets of trains on Thameslink, the Great Western Main Line and the East Coast Main Line (and, critics would argue, it shows). But in this affair, as with the May timetable fiasco, they have been content to shrug and walk away. Back in 2015, Claire Perry as rail minister was asked by Lillian Greenwood, Labour’s shadow transport minister at the time, what she was doing about the problem of the HSTs on the Midland Main Line: she gave a classic ‘I have been having meetings…’ type answer. Last year, her successor Paul Maynard was questioned on the subject and observed it was the train operating company’s responsibility to source trains (even though a new operator could well be in place when the regs change, HMG has specified trains for other operators, and the operator has clearly failed to do anything about a long-known problem). Current rail minister Nusrat Ghani replied to a parliamentary question on the topic by observing that the Department would consider the industry’s ‘preferred solution’ once it had come up with it. So my dig about screw-ups earlier wasn’t careless: ministers were incapable of stepping in to stop the May 2018 timetable foul-up, and have shown a total unwillingness to act here – so maybe we really will get to 2020 and suddenly find the Midland Main Line does not have enough trains.
‘Major Midland meltdown’ – Richard Clinnick, Rail 842, December 20th 2017
‘£50m price tag on MML HST accessibility modifications’ – Richard Clinnick, Rail 849
‘Midland Mk 4’ – Ian Walmsley, Modern Rail March 2018
‘Mk 4s on the Midland’ – Gareth Dennis, Rail 850, April 11 2018
News article, Rail 850, April 11 2018
News article, Modern Railways, May 2018