• Our booking engine at tickets.railforums.co.uk (powered by TrainSplit) helps support the running of the forum with every ticket purchase! Find out more and ask any questions/give us feedback in this thread!

'EU regulations would prevent ensuring level access for disabled people on HS2': Is Grayling right?

Status
Not open for further replies.
Sponsor Post - registered members do not see these adverts; click here to register, or click here to log in
R

RailUK Forums

Starmill

Starmill

Veteran Member
Joined
18 May 2012
Messages
23,393
Location
Bolton
swt_passenger said:
It has been regularly discussed here that the TSIs platform height does not allow for level access.
Click to expand...
This may well be correct.

It does not neccesarily mean that it is a good idea to oppose the regulations completely (which is what Mr Grayling suggests, according to the article) or that "EU regulations would prevent ensuring level access for disabled people on HS2" given that derogations are clearly possible.
 
Last edited:
fowler9

fowler9

Established Member
Joined
29 Oct 2013
Messages
8,367
Location
Liverpool
I'm going to stick my neck out and say this is nailed on to be utter rubbish. I bet the EU do not enforce level access as long as there is access. To say that the EU will not allow level access will be Grayling being an incapable idiot twisting words as always. Can anyone back this nonsense up?
 
E

edwin_m

Veteran Member
Joined
21 Apr 2013
Messages
24,927
Location
Nottingham
There is an issue here to some extent but I think Grayling is inflating this out of all proportion to suit his pro-Brexit views. There are plenty of UK-specific clauses in the TSIs, it is possible to change them as shown by several updates since they were originally issued, and they already have two high speed platform heights in the TSI to suit what France and Germany had already done. As with the overhead line clearance standards, the problem is likely to be down to the UK being unwilling or unable to engage fully with the process and get its own views taken into account, rather than infexibility on the other side.

Of course the deal that Grayling has just signed up to as part of collective cabinet responsibility does leave the UK in a state of following the rules with no formal influence in setting them, and this could be indefinite unless some other way is found of resolving the intractable Irish border issue. This makes it less likely that a UK-specific variation will happen, although I suspect the international rail bodies would be pragmatic and listen to the UK point of view even if not legally obliged to. But if that's where we end up then Grayling has only himself and his fellow Brexiteers to blame, for hoodwinking the public into voting for something that will solve few of the UK's problems and make many of them much worse.
 
D

daikilo

Established Member
Joined
2 Feb 2010
Messages
1,623
Brussels is really only concerned about transborder traffic/lines, the safety of EU citizens travel and the ability of companies to trade in any EU country.

In my opinion, many statements "Europe does not allow …" are in fact not backed up by fact or possible interpretation. This is particularly true for UK rail due to the specifics of the loading gauge. Indeed, disabilities and equal access are very high on the EU agenda so any rule which "unnecessarily" limits it would be contestable even for an EU country.

As regards level boarding, it is a combination of platform and door heights, and Stadler was quite happy to adjust the latter to Merseyrail desires. I suppose that if HS2 chose a platform height which made loading say IC3 or AGV difficult, their builders could try contesting as long as the EU purchasing rules are applied, but I more than doubt that they would given that others certainly won't.

One detail which does concern me is that the govt. has stated there intent of having a repeal bill which will actually adopt all EU laws which are not yet on UK statute books (probably meaning that at that point the UK will be the most EU of any European country). This could lead to some unwanted surprises.
 
Last edited:
B

Bletchleyite

Veteran Member
Joined
20 Oct 2014
Messages
97,879
Location
"Marston Vale mafia"
daikilo said:
As regards level boarding, it is a combination of platform and door heights, and Stadler was quite happy to adjust the latter to Merseyrail desires. I suppose that if HS2 chose a platform height which made loading say IC3 or AGV difficult, their builders could try contesting as long as the EU purchasing rules are applied, but I more than doubt that they would given that others certainly won't.
Click to expand...

Stadler already do a low-floor high-speed train, as the Swiss were insistent on it. If there is a demand for one, if others want the business they need to develop one. There is nothing stopping them doing so, and therefore the requirement really isn't anticompetitive.

Actually, Alstom too - the TGV Duplex is level boarding, isn't it? Just because DB prefer high floor stepped entrances for their ICEs doesn't mean it can't be done. After all the Polish ordered a high floor FLIRT with stepped entrances despite all the others ordered by other countries (including the UK, which doesn't traditionally do that) being low-floor.
 
Last edited:
G

Gems

Member
Joined
10 Nov 2018
Messages
656
Whilst every other politician are coming out with strong and convincing argument for or against Brexit. Failing can only come out with this nonsense.
 
G

Gerald Fiennes

Member
Joined
7 Jan 2009
Messages
864
Notwithstanding the pros and cons of EU membership, TSIs are not the greatest advertisement for Europe. The current TSI platform height levels (there are a number of them available) are too low for level boarding so one solution is indeed lower deck height on the train. Another is to seek a derogation. Another is wonder whether the Commission would try any kind of enforcement if the UK did diverge from the TSI: probably not, but so long as the UK remains a member the country would doubtless continue to take a very correct view on these matters and follow the TSI rules precisely whether or not there was any enforcement. On paper, it would be great if everyone followed the same standards for everything from the perspective of economies o scale, but the cost of doing something different on a project by project basis is not that high (since most UK rolling stock is bespoke in reality due to the country's 'first mover disadvantage'). In reality, there is no particular magic to most of the TSIs.
 
B

Bletchleyite

Veteran Member
Joined
20 Oct 2014
Messages
97,879
Location
"Marston Vale mafia"
Thinking on, I suppose the main difficulty is classic-compatible stock, which unless the HS2 platform height is the present UK platform height means there will only be level boarding on *either* HS2 *or* the classic lines unless there are two sets of doors and a ramp inside the train. But given that the Chinese height was being proposed for HS2 (very high floor), the TSI does nothing at all to prevent this - the UK's own decisions already prevented it. The only way to get level boarding throughout is to retain the present UK platform height for HS2 - which, to be honest, does make sense, and realistically probably would obtain a derogation because there aren't going to be through trains past St Pancras any time soon, or even ever, really.
 
N

notverydeep

Member
Joined
9 Feb 2014
Messages
878
I think this may be a case of two good things clashing. The TSIs are designed to promote interoperability, which in turn would allow more seamless movement of people and goods within the EU. On the continent, there was / is wide spread use of platforms that are low or very low by UK standards, which in turn allowed quite wide car bodies at low level - which would foul UK platforms (even if the vehicles could fit under the low bridges) and often require several steps to board.

EU disability rules were conceived within this context and largely make sense when applied to it, given the very high cost of systematically changing it across the continent. Neither these rules nor the TSIs were developed with the rather different loading gauge in use in the UK and the associated historic use of quite high platforms in mind. Although new railways could be built to continental like practices (as for example the International platforms at St. Pancras, this would make interoperation with the rest of the UK network more problematic and HS2 trains will need to be able to interoperate, hence the desire for HS2 to fit into the High Platform style of operation. There is a history of suitable derogations to EU TSIs that recognise the different UK context, but why acknowledge that when not doing so helps confirm your world view...?
 
Last edited:
MarkyT

MarkyT

Established Member
Joined
20 May 2012
Messages
6,251
Location
Torbay
The ERA, Europe's rail agency, ruled against the derogation for HS2 platform height, recommending instead that the standard UK height should be used with UIC lateral clearances. Alstom and Talgo both have low floor VHS trains that could be adapted easily to the UK height. Stadler haven't yet built a true very high speed unit yet. The SBB trains are good for 250kph, the Anglians 200kph. They've not created a 300+kph Velaro or AVG equivalent so far. Interesting that the low floor revolution is driving a return to separate power cars, rather than the fully distributed drive favoured by the Far Eastern and German manufacturers. The problem is accommodating the big power bogies with large wheels beneath the car. At least with a trailer bogie you can avoid ramps by creating a low floor passage between the tops of the wheels. The Talgo design even allows the interior floor to drop below the centre of the wheel as it doesn't have a conventional axle. 915mm floor height platforms AND trains on HS2 would offer level(ler) boarding benefits at all the classic stations to be served as well as the new platforms, if it can be achieved, but only certain manufacturers today could do that, so by going for the Asian height I guess they figured there'd be a wider choice of train suppliers.
 
MarkyT

MarkyT

Established Member
Joined
20 May 2012
Messages
6,251
Location
Torbay
I should point out that the relvant TSI already allows any new platforms in the UK to be our traditional 915mm height. There's never been an intention by the EU to try and change that as it is a neccesity for local interoperabilty. There are a series of national variations allowed, relating to gauge, platforms, power supply etc.
 
E

edwin_m

Veteran Member
Joined
21 Apr 2013
Messages
24,927
Location
Nottingham
MarkyT said:
I should point out that the relvant TSI already allows any new platforms in the UK to be our traditional 915mm height. There's never been an intention by the EU to try and change that as it is a neccesity for local interoperabilty. There are a series of national variations allowed, relating to gauge, platforms, power supply etc.
Click to expand...
Is that true for high speed lines or only conventional?

My understanding is that the high speed TSI dictates plaform heights, from a choice of two (possibly more in a more recent update), for interoperability reasons. Unfortunately it's difficult or impossible to achieve this except perhaps with the TGV double deck design where the doors are intermediate between the two levels.
 
B

Bletchleyite

Veteran Member
Joined
20 Oct 2014
Messages
97,879
Location
"Marston Vale mafia"
MarkyT said:
The ERA, Europe's rail agency, ruled against the derogation for HS2 platform height, recommending instead that the standard UK height should be used with UIC lateral clearances.
Click to expand...

Which I would agree with, as it means the classic compatible trains will be level boarding at both standard UK platforms and on dedicated HS2 ones. A sliding step can be used to bridge the gap as per all FLIRTs.

Ramps are not really an issue because wheelchair users generally do not need to move between coaches, and indeed a common "Euro-EMU" arrangement is of a low floor centre section between the bogies and steps up to the end sections above them.
 
HSTEd

HSTEd

Veteran Member
Joined
14 Jul 2011
Messages
16,734
swt_passenger said:
I think he is probably right. It has been regularly discussed here that the TSIs platform height does not allow for level access.
Click to expand...
The TSI platform height does not allow for level access in the stock that HS2 LTd would prefer they use, there are plenty of trainsets available that would allow this.

HS2 Ltd's height would also have prevented any double decker trains

edwin_m said:
Unfortunately it's difficult or impossible to achieve this except perhaps with the TGV double deck design where the doors are intermediate between the two levels.
Click to expand...

The TGV Duplex boards directly onto the lower deck IIRC.
 
T

Tio Terry

Member
Joined
2 May 2014
Messages
1,178
Location
Spain
I'm somewhat at a loss to understand why Grayling thinks the UK cannot comply with the PRM TSI requirements. There is specific provision for platforms of nominal 915mm height within Table 25 of the document. If it is referring to existing infrastructure then the TSI does not, in general, apply but there is allowance for and recommendations for, the use of ramps - something that happens across the network every day.
 
D

daikilo

Established Member
Joined
2 Feb 2010
Messages
1,623
HSTEd said:
The TGV Duplex boards directly onto the lower deck IIRC.
Click to expand...

Duplex doors are about 2 steps up from the lower-deck main floor and lead onto a platform from which the stairs rise to the upper deck or separately descend to the lower. The height of the ceiling above the door is local to that area. I do not know how PRM wheelchairs are handled unless they remain on the said 'platform'.
 
MarkyT

MarkyT

Established Member
Joined
20 May 2012
Messages
6,251
Location
Torbay
edwin_m said:
Is that true for high speed lines or only conventional?
My understanding is that the high speed TSI dictates plaform heights, from a choice of two (possibly more in a more recent update), for interoperability reasons. Unfortunately it's difficult or impossible to achieve this except perhaps with the TGV double deck design where the doors are intermediate between the two levels.
Click to expand...
The fact the ERA recommends 915mm suggests it is a permitted on new HS lines in UK, for domestic interoperability.
https://www.era.europa.eu/sites/def...opinion-advice/opinion_era-opi-2015-10_en.pdf
In conclusion, it is our opinion that the best interests of the UK railway and all of its passengers is to use the current UK specific case of 915 mm arl. Given the potential size of the rolling stock order, train manufacturers will come with their solutions that create level access to the train, if not through the train. Some 60% of train services during phase 1 and more than 45% during phase 2 will serve towns and cities off the HS2 network. We believe this approach will allow the new trains to be fully and easily accessible to all users not just those using stations on the HS2 network.
Click to expand...
HSTEd said:
HS2 Ltd's height would also have prevented any double decker trains
Click to expand...
Perhaps not prevent entirely but would probably preclude a continuous top deck as in latest Alstom duplex products
HSTEd said:
The TGV Duplex boards directly onto the lower deck IIRC.
Click to expand...
This video of the latest Avelia Horizon suggest two steps down from entrance door to low level. Not sure which platform height this would apply to but I understand SNCF is standardising on 550mm
In these, the upper deck is continuous and there is no gangway through between cars on the lower. Looks like entrance height could be adjustable upwards without reducing seating, but clearly not with level access, and with extra steps. They cater for PRM at selected doors with a special lift/turntable arrangement. Early publicity from Alstom for the HS2 bid featured an Avelia based solution with common power cars that could sandwich either a rake of single deck Phase 1 cars or larger, captive bi-levels later.
 
Last edited:
HSTEd

HSTEd

Veteran Member
Joined
14 Jul 2011
Messages
16,734
daikilo said:
Duplex doors are about 2 steps up from the lower-deck main floor and lead onto a platform from which the stairs rise to the upper deck or separately descend to the lower. The height of the ceiling above the door is local to that area. I do not know how PRM wheelchairs are handled unless they remain on the said 'platform'.
Click to expand...

The interesting this is that the TGV Duplex is only a GB+ gauge vehicle, which means HS2 could make them significantly taller (330mm)

That would largely allow a flat deck on the lower deck whilst retaining a continuous upper gangway, with the standard TSI platform height.
You would be able to manage single step boarding at 915mm, but you've got no chance at all at HS2's ludicrous proposed 1300mm platform height.
 
T

Tio Terry

Member
Joined
2 May 2014
Messages
1,178
Location
Spain
It seems I have mis-understood the problem.

Why ever is HS2 proposing a platform height of 1300mm?

Trains that use HS2 but come from other network locations where the platforms are at or about 915mm will all need ramps to cater for the around 385mm step!

This is nothing whatsoever to do with the PRM TSI, this is totally down to the UK attempting to do something that the TSI does not consider.

Why 1300mm?
 
T

Tio Terry

Member
Joined
2 May 2014
Messages
1,178
Location
Spain
Bletchleyite said:
Because China uses a platform height of around that, and they want to buy Chinese built trains on the cheap.
Click to expand...

But they won't be cheap if every station on the current national network that has a service that stops at it that then traverses HS2 has to be equipped with ramps that meet the PRM TSI requirements and, in many cases, have platform alterations to allow them to be utilised?
 
J

JamesT

Established Member
Joined
25 Feb 2015
Messages
2,694
Tio Terry said:
It seems I have mis-understood the problem.

Why ever is HS2 proposing a platform height of 1300mm?

Trains that use HS2 but come from other network locations where the platforms are at or about 915mm will all need ramps to cater for the around 385mm step!

This is nothing whatsoever to do with the PRM TSI, this is totally down to the UK attempting to do something that the TSI does not consider.

Why 1300mm?
Click to expand...

If I’m reading figure 13 of https://www.whatdotheyknow.com/requ...ccess At the Platform Train Interface PTI.pdf correctly, the floor of a Mk3 carriage is at 1245mm. That sounds like a fairly representative example of the stock we currently have on the network. HS2 are proposing a height of 1200mm, so you’d get level boarding on the captive sections and you’re no worse off height wise on the classic network.
 
B

Bletchleyite

Veteran Member
Joined
20 Oct 2014
Messages
97,879
Location
"Marston Vale mafia"
JamesT said:
If I’m reading figure 13 of https://www.whatdotheyknow.com/request/360478/response/885162/attach/4/161020 HS2 HS2 EN REP 000 000016 P04 Level Access At the Platform Train Interface PTI.pdf correctly, the floor of a Mk3 carriage is at 1245mm. That sounds like a fairly representative example of the stock we currently have on the network. HS2 are proposing a height of 1200mm, so you’d get level boarding on the captive sections and you’re no worse off height wise on the classic network.
Click to expand...

Whereas if they go for UK platform height and low floor, they can have level boarding everywhere.

TBH, I think this should be mandated for all new stock without exception, effective immediately. The benefits are immense.
 
Status
Not open for further replies.

Top