Closed consultation

RVAR 2010 exemption: London Underground Limited Bakerloo line platforms

Published 29 February 2024

This was published under the 2022 to 2024 Sunak Conservative government

This application is structured into a background and one topic section, which covers station platforms for which an exemption is sought.

Full name of the applicant

Richard Jones, Director of Asset Performance Delivery

Address of the applicant

London Underground Limited
5 Endeavour Square
London E20 1JN

Background

The 1972 stock rail vehicles currently operate on the Bakerloo line that runs from Harrow and Wealdstone in north-west London to Elephant and Castle in south London.  The line serves 25 stations, 15 of which are underground, over 23.2 kilometres. It interchanges with other services at:

• London Paddington
• Marylebone
• Waterloo
• Oxford Circus
• other stations

All stations north of Queen’s Park are compromise height platforms owned by Network Rail. The Bakerloo line runs on both London Underground (LU) owned infrastructure (Elephant and Castle to Queen’s Park) and Network Rail (NR) owned infrastructure (Queen’s Park to Harrow and Wealdstone) under an operating licence.

Exemption orders made to date

To date, one RVAR exemption order has been made, as shown in the published list-of-rvar-exemption-orders. It is 2019 Order, for 1972 tube stock (PDF).

Section 1: platforms

Description of the platforms where the application relates

Exemptions are sought about platforms at the following Bakerloo line stations where the rail vehicles serve:

• Charing Cross
• Edgware Road
• Embankment
• Harlesden
• Kensal Green
• Kenton
• Kilburn Park
• Lambeth North
• Maida Vale
• Marylebone
• North Wembley
• Piccadilly Circus
• Queen’s Park
• Regent’s Park
• South Kenton
• Stonebridge Park
• Waterloo

Services provided

Normal services are provided at these times.

Time of the week	First or last train	Harrow and Wealdstone to Elephant and Castle	Elephant and Castle to Harrow and Wealdstone
Weekday	First Train	05:39	05:37
Weekday	Last Train	23:54	23:47
Weekend	First Train	07:19	07:16
Weekend	Last Train	23:12	23:26

The exemption provisions of RVAR

Schedule 1, part 1 (general requirements): boarding devices at wheelchair-compatible doorways.

London Underground has developed an approach with the Department for Transport (DfT) and Disabled Persons Transport Advisory Committee (DPTAC) (which was subsequently agreed in Parliament) called the ‘Pimlico principle’.  This is based on a precedence set at Pimlico station, which does not have any access to platform level or interchange by step-free routes.

If the platform train interface (PTI) was made compliant, passengers would still be unable to leave the platform to make onward journeys without step-free access from platforms to street level. The Pimlico principle approach was developed during the Victoria Line upgrade exemption in 2008.

This was subsequently used for the ‘S8’ Metropolitan line exemption application in 2009 and ‘S7’ application in 2011. It was supported as a pragmatic approach by all involved during the debates in Parliament for both applications.

To date, this principle has been applied to the:

• Bakerloo line
• Central line
• Jubilee line
• Piccadilly line
• Northern line

This allows platforms that do not fit into one of the following 3 categories:

• a station that provides step-free access from street level to platform

• a station that is planned to provide step-free access from street level to platform

• a station that provides useful (and step-free) interchanges or is a terminus

London Underground defines access where passengers can use lifts or ramps between the street and the platform or/and trains and reach the trains or the surface as ‘step-free’. These do not always create level access between the platform and the train.

Where platform access is level for the RVAR nominated doorways, it is in line with RVAR requirement as follows:

• maximum gap of 75 millimetres (mm)

• maximum step of 50mm

Platforms that do not fit into any of these categories are labelled category 4: referred to as ‘Pimlico platforms’ and do not require wheelchair access between the train and the platform. However, this approach can only apply to LU-owned infrastructure south of Queen’s Park. 

NR-owned platforms serve the London Overground, Class 378 trains (with a higher floor height) and are compromise height, resulting in a step down into Bakerloo line trains. If these platforms were lowered or the track was raised, to give level access for Bakerloo line trains, there would be an unacceptable step for Class 378s.

Therefore, on Network Rail infrastructure, the only practical solution to achieve RVAR compliance is to implement manual boarding ramps (MBRs), other than stop inter-running or inter-berthing of these fleets, when the access is step-free from street to platform. London Underground has met this requirement and provided MBRs on the platforms at:

• Harrow and Wealdstone
• Wembley Central
• Willesden Junction

There are 11 Pimlico platform stations owned by London Underground and 7 stations owned by Network Rail – not bound by the Pimlico principle, in this application. All of these, including those operated by London Underground, seek an exemption from paragraph 1(1) of Schedule 1 RVAR relating to the provision of a boarding device at a wheelchair-compatible doorway when it is open at a platform listed in the tables below.

Table 1: London Underground owned stations

LU-owned station	Platforms
Charing Cross	1, 2
Edgware Road	1, 2
Embankment	5, 6
Kilburn Park	1, 2
Lambeth North	1, 2
Maida Vale	1, 2
Marylebone	1, 2
Piccadilly Circus	1, 2
Regent’s Park	1, 2
Warwick Avenue	1, 2
Waterloo	3, 4

Table 2: Network Rail owned stations

NR-owned station	Platform
Harlesden	1, 2
Kensal Green	1, 2
Kenton	1, 2
North Wembley	1, 2
Queen’s Park	2, 3
South Kenton	1, 2
Stonebridge Park	1, 2

Technical, economic and operational reasons for the application

Platform and train level access between trains and platforms is not possible in some locations (platform humps, nosing realignment, or track-raising) from the technical perspective. The platforms serve different types of rolling stock and tracks that have different platform to train heights/gaps.

Central London station platforms are also deep underground and are constrained by the station orientation and interfaces with other asset owners, tunnel and track infrastructure. It is extremely expensive to make deep underground stations step-free. Works are highly complex involving intrusive civil works, services and utilities diversions, which will disrupt users in both the station and surroundings. 

The RVAR requirement states that where the step and gap between the train and platform are greater than 50mm and 75mm respectively, a manual boarding ramp is to be provided to assist a wheelchair user to board and alight the train.

London Underground’s preferred method is to bring the gap between the train and the platform into compliance by installing platform humps. Meeting the gap requirement, however, is only possible on relatively straight platforms with relatively straight track with a ‘step-up’ interface between train and platform. When this is not the case, the MBRs are used. If there are service or safety impacts that MBRs would have, as in the case of Queen’s Park station, an exemption would be sought.

Exemptions are requested under the Pimlico principle at LU-owned locations where there are no possible step-free journeys from train to platform and onward to ticket hall/street level.

For NR-owned infrastructure, London Underground is also seeking exemptions to operate at these non-step-free stations. The list for which exemptions are sought and under the relevant circumstances is outlined below.

Table 3: London Underground-owned infrastructure

Station	Factor: technical	Factor: cost	Rationale for exemptions
Charing Cross	Yes	Yes	Limited space to fit a lift between the platforms and waiting area, assuming a suitable location could be found to build a lift shaft from ticket hall/street level
Edgware Road	Yes	Yes	Highly disruptive lift installation between lower concourse and platform levels. Risk of re-construction and remodelling of building
Embankment	Yes	Yes	Technically challenging and highly disruptive to demolish and rebuild access to platforms for lift installation. Potential for future line extension programme to investigate station improvements, subject to capital funding
Kilburn Park	Yes	Yes	Heritage station with Grade II listed status. This requires significant excavation for a lift shaft in a confined space at close proximity to an escalator barrel
Lambeth North	Yes	Yes	Limited space and layout to allow lift installation between the platforms physically
Maida Vale	Yes	Yes	Heritage station with Grade II listed status. Technically challenging and highly disruptive to construct, complicated by the ticket hall being located at basement level
Marylebone	Yes	Yes	Site constraints given the station orientation, layout and connection to NR mainline services
Piccadilly Circus	Yes	Yes	Heritage station with Grade II listed status. Convoluted way to install lifts from ticket hall to platform level which may be possible to reutilise disused lift shafts and associated passageways. Highly disruptive and requires a satellite ticket hall for access
Regent’s Park	Yes	Yes	Complex and highly disruptive to install lifts between lower concourse and platform levels. Noting that the ticket hall is located beneath Crown Estate gardens and restricts lift installation and access
Warwick Avenue	Yes	Yes	Technically challenging and highly disruptive to construct, complicated by the ticket hall being located at basement level
Waterloo	Yes	Yes	Complex interchange affecting several lines. Step-free access is available on the southbound Bakerloo line platform and a scheme was previously identified to provide access to the northbound. Both platforms are severely curved, which makes the platform-train interface difficult to implement. Refer to Appendix A for more information

Table 4: Network Rail-owned infrastructure

Station	Factor: technical	Factor: cost	Rationale for exemptions
Harlesden	Yes	Yes	Potential inclusion in the West London Orbital scheme, to provide an out-of-station interchange with the Bakerloo line, subject to capital funding and NR infrastructure protection agreement
Kensal Green	Yes	No	Site and station layout constraints challenging to identify lift locations for step-free route and modification
Kenton	Yes	No	Site and station layout constraints made it challenging to identify lift locations for step-free route and modifications
North Wembley	Yes	No	Site constraints given the station layout and adjacent to NR mainline
Queen’s Park (*)	Yes	No	It is operationally unsafe for staff to deploy MBR on the northbound platforms. Emergency ramp remains for detrainment only. The station was considered in the Network Rail ‘Access for All’ programme for step-free access scheme; subject to capital funding
South Kenton	Yes	No	Significant infrastructure and civils required to build a new subway through the embankment to access a lift to platform level
Stonebridge Park	No	Yes	Potential for inclusion in the future Network Rail ‘Access for All’ programme: subject to capital funding and NR infrastructure protection agreement

(*) Queen’s Park is an exception in that it is NR-owned and does not have a compromise height platform. Therefore, platform humps and MBR provision were investigated.

Effect of non-compliance on a disabled person’s ability to use the rail vehicles

London Underground has sought to minimise the effect of these exemptions on disabled people’s ability to travel. By using a combination of platform ‘humps’ and MBRs at major step-free stations, a person with reduced mobility will be able to reach parts of the Bakerloo line that would otherwise have no provision for customers with mobility impairments to embark or disembark from train to platform.

Since 2019, London Underground has delivered the below works as stipulated in Section 3 (a) of Schedule 1 of the previous Exemption Order. The non-Pimlico principle platforms have been altered and where technically impossible to modify, MBRs have been supplied under the timed exemptions, for example, Paddington station.

This allowed for the MBRs and platform ‘humps’ to comply with the Rail Vehicle Accessibility (Non-Interoperable Rail System) (London Underground Bakerloo line 72 Tube Stock) Exemption Order 2019 granted on 11 December 2019.

Table 5: platform hump installation

Station	Platforms
Oxford Circus	3, 4
Paddington	3

Table 6: provision of MBRs

Station	Platform
Baker Street	8, 9
Elephant and Castle	3, 4
Harrow and Wealdstone	1, 2
Paddington	4
Wembley Central	1, 2
Willesden Junction	1, 3

It is impractical to make all stations step-free on the line due to the constraints. Therefore, trained staff will be deployed to use a ramp at some stations to provide step-free access from train to platform. 

Assistance is available on a ‘turn up and go’ basis meaning that delays to a journey are minimised as much as practical and without advanced planning: and at selected stations included in the accessible travel policy (ATP), advanced booking is required. This service will be provided on Bakerloo line stations interchanging with London Overground and National Rail services:

• Harlesden
• Harrow Wealdstone
• Kensal Green
• Kenton
• Queen’s Park
• South Kenton
• Stonebridge Park

The measures proposed, if the application is granted, to enable a disabled person to use the rail vehicle

London Underground provides advice on alternative routes and step-free stations for disabled persons to use the Bakerloo line services and other modes through our range of transport accessibility services. These include:

• travel advice (guides, maps and journey planners, such as step-free and avoiding the stairs tube guides)
• passenger assist service with National Rail services
• travel mentoring
• assisted transport services (door to door)

Where assistance is required at interchanges, London Underground also offers a ‘turn up and go’ service together with Elizabeth line and London Overground. Soon, as part of our accessible travel policy (ATP), we will be offering prebooked luggage assistance at 30 stations interchanging with train operating companies (TOC). 

Transport for London (TfL) is also continuing work to increase the number of step-free stations on the London Underground network, which has increased by 20% since 2016.  There are now more than 200 step-free access stations on the TfL network of which 92 are Underground stations. A further 10 stations are being prioritised for further examination to understand feasibility and costs following a public consultation in 2021. Which of these become step-free depends on the outcome of the current work, as well as on available budgets in future years. Further stations may be added to our programme. Again, this depends on available funding.

The majority of public respondents captured in the 2021 public consultation on step-free access felt that interchange stations with other Tube lines or modes of public transport (for example, trains and buses) should be prioritised, as well as those that are within easy reach of hospitals/healthcare services.

Where these stations are considered, they should be those in a specific area or on lines where there are gaps of minimal access (for example, to ‘plug a gap’ in the Tube network). We envisage as the step-free network continues to expand, there will be more accessible travel options for all our customers.

Within the financial constraints, TfL looked at buildability of step-free access in terms of costs, risks, disruptions and benefits. None of the LU-owned Bakerloo line stations are currently identified to be made step-free from street to platforms affordably.

Although independent journeys can be made in the majority of our network, many of the platforms were never designed to provide step-free and level access. Where step-free from train to platform is possible, trained London Underground staff will fit in a permanent platform hump and, where impossible, MBRs will be provided. 

Exemption order request: timeframe

London Underground is seeking exemptions to provide a boarding device when the vehicles are stationary at these specified platforms including Queen’s Park. There is no step-free access for users to enter, exit or interchange with another London Underground or Overground service.

Travel information (step-free tube guide) has also been amended by removing Queen’s Park as an accessible/interchange station using MBRs as it had previously been shown. By granting this exemption request, there will be a total of 18 station platforms that will not comply with Schedule 1, Part 1 (General Requirements).

London Underground recommends that the exemption order is made until 31 December 2029 to be reviewed by which time, a decision on the Bakerloo line fleet replacement will be confirmed and station accessibility improvements at both LU-owned and NR-owned infrastructure will be agreed. The extension is sought to develop feasibilities to comply with RVAR requirements and conditions as the Secretary of State for Transport may prescribe.

Replacement of Bakerloo line trains, depot and associated infrastructure works are dependent on government funding. We have a contract with Siemens Mobility Limited which includes a time-limited (by 1 November 2026) option for the Bakerloo line fleet. If the option cannot be exercised within that time frame a separate procurement for new Bakerloo line trains will be required in the future setting back replacement of the fleet until the mid to late 2030s. This would require exemptions to be further extended beyond 2029 and jeopardise the future operation of the Bakerloo line given the age and condition of the current fleet.

The above timescales are indicative based on current assumptions to enter into the contractual option with Siemens Mobility Limited. Infrastructure works relating to RVAR will be subject to feasibility and agreements from station infrastructure owners and operators other than London Underground specifically Network Rail and London Overground.

Prior consultation with vehicle operator

London Underground is the owner and operator of the rail vehicles. Therefore, there are no consultation responses to report.

How to respond

If you have any comments or feedback you would like to provide regarding this consultation, you will find contact details under our ways to respond section.

The consultation period began on 29 February 2024 and will run until 11:59pm on 28 March 2024. Please ensure that your response reaches us before the closing date.