Can you clarify for me konstant, are you stating that there would now be an issue with the continued/long-term use of any non-end-door stock through the Blaenau tunnel (possibly including a 150/1 or 221 that has operated there previously), or that the Class 230 would not be allowed to operate through the tunnel at all, because as a new design it would need to pass a revised risk assessment? Or is it perhaps a combination of both?
Either way, the class 230 is only planned to be used there for a few years before moving to the Borderlands full time. If permission were denied for the Conwy Valley, it might be used elsewhere, say on Crewe-Shrewsbury stoppers, instead. (Though it might not release a full 150 diagram for PRM modifications as intended.)
The vehicles will require to undergo a formal assessment against various railway standards as part of their entry into service and in pursuit of the all important letter of authorisation from the regulator. One of the many standards of which the vehicles performance will be measured against is GM/RT2130. Clause 7.1.1 is where this headache, among others, may arise. The operator will need to demonstrate that the risk of evacuating the train in tunnels of restricted width such as those on the line in question is not impeded by the design of the vehicle. If it is, the vehicle will need to be modified to include end doors. This is not as easy as other people have suggested, infact it's probably one of the most significant changes that can be imagined on a vehicle of this type. The entire basis of the cab and its subsequent approvals, including all human factor considerations, let alone sighting distances, layout, and even the communication between a driver and second man which would need to be reviewed and inevitably changed. The structure, and substructure, plus the entire drivers desk, would need to be changed, and the process of review and arbitration with bodies such as ASLEF would start again. This is a process which takes years typically, which would cause rather a delay to a vehicle due to enter into service two months ago.
A 150, 221, or anything else for that matter already cleared for operation on this route would not be affected by this decision. Those vehicles have or have had clearance in the past and that's all they need. For instance, a 150 may have operated on the route in the past, and didn't have a PRM compliant toilet, but that's no excuse at all to justify not fitting a PRM compliant toilet to the Class 230.
The argument that it's only going to be there for a few years or months before moving is irrelevant. If one of the units catch fire again, inside a tunnel, on day one, this argument and the persons whom authorised it might find it difficult in a court of law to defend their approach.
The current version of GM/RT2130 is Issue 4, which was issued in December 2013. Other vehicles which when new predate this date, will have had to conform to a different version or standard altogether, which makes any comparison of the Class 230 against any other fleets authorisation or ability to operate on this route irrelevant in the eyes of the regulatory bodies which will be asked to provide their view on this vehicle.
I would like to place my flag in the ground now and state that I am a fan of the Class 230 project and wish Vivarail every success with what is fast becoming a ground breaking project with unusually strong environmental credentials. I will not however let this cloud my judgement on a manufacturer making a deliberate attempt to bypass the process for introducing a new vehicle onto the railway network. These rules are for a reason, one only has to read Red for Danger to understand why we develop and change rules on the railway.
