Open consultation

Rail vehicle dispensation: Great Western Railway Class 230 fast charge unit

Published 26 September 2025

Dispensation request

Vehicles that the application refers to:  

Great Western Railway seeks the Department for Transport’s approval for dispensation against requirements of the Accessibility National Technical Specification Notice (ACC NTSN) for its Class 230 3 car unit 230001 with the vehicle numbers below.

Vehicle numbers:

• unit 230001: vehicles 300001, 300201 and 300101

Manufacturer:

• built by Metro-Cammell, Birmingham, 1979 to 1983 (London Underground D78 stock)
• re-built by Vivarail, Southam, 2016
• converted to battery-electric multiple unit (BEMU) by Vivarail, 2021

Services and routes operated by the vehicles 

GWR proposes to bring unit 230001 into service between Greenford and West Ealing. It has been operating on the route in non-passenger service for 18 months since March 2024 as part of the Fast Charge Trial.

Provisions of ACC NTSN for which dispensation is sought

The vehicles of this unit do not comply with the following requirements in the ACC NTSN:

• 4.2.2.3.2.(8)(d) door closing signal when door is closed locally by passenger or crew
• 4.2.2.3.2.(15) height of exterior door controls
• 7.3.2.6 step position for vehicle access and egress

Explanation of non-compliances

ACC NTSN section 4.2.2.3.2.(8)(d) door closing signal

When a door is closed locally (by a passenger or crew), a door closing signal shall be given; it shall start following the operation of the control device and shall continue until the door is closed.

Applicant’s explanation

230001 does not do this, and neither do other Class 230s already in passenger service (unit numbers 230006 to 230010 with Transport for Wales, and units 484001 to 484005 on the Island Line). This requirement was introduced with the publication of ACC NTSN (May 2025), whereas the door system on 230001 was designed when the Persons with Reduced Mobility (PRM) NTSN (January 2021) was in force.

While every effort is being made to comply with ACC NTSN wherever possible, making a change to the door system to deliver this requirement would be complex and expensive. In mitigation, if a door is closed locally by a passenger or crew, it would be with obvious intent, and it would be reasonable to expect that they would warn anybody in the vicinity that they were about to close the doors.

ACC NTSN section 4.2.2.3.2.(15) height of exterior door controls

The centre of exterior door opening control, operable from the platform, shall be not less than 800mm and not more than 1200mm measured vertically above platforms, for all platforms for which the train is designed. If the train is designed for a single platform height, the centre of exterior door opening control shall be not less than 800mm and not more than 1100mm measured vertically above that platform height.

Applicant’s explanation

The centre of the door opening control is approximately 1300mm above platform level. This dimension is determined by the existing hole for original controls. This is 100mm higher than the specification when measured against a ‘standard’ platform height of 915mm.

To meet the required height would necessitate an alteration to the vehicle structure. We note the provisions in Appendix F of the ACC NTSN, which state that compliance is not mandatory if the work would require structural alterations, including to door portals. We also note that 230001 will be operated in driver-controlled operation (DCO) mode, as with the Class 165 diesel multiple units that operate the existing Greenford to West Ealing service.

Bodyside CCTV cameras on 230001 allow the driver to monitor the platform train interface (PTI) and if anybody is struggling to reach the buttons, this will be picked up by the driver, who will be able to provide assistance. Furthermore, when the doors are ‘released’ or closing, a warning is sounded. For people standing outside the train, this warning sound emanates from a speaker embedded in the panel containing the external door pushbuttons. This will help draw blind or partially-sighted people to the location of the buttons.

ACC NTSN section 7.3.2.6 step position for vehicle access and egress

Step position for vehicle access and egress section 4.2.2.11.1(3) refers to section 7.3.2.6, which states:

UK Specific Case (Great Britain) ‘P’ for all rolling stock intended to stop, in normal operation at platforms of nominal 915 mm height: Passenger access steps for the vehicle shall be designed to meet the requirements set out in the National Technical Rules.

Applicant’s explanation

Unit 230001 does not comply with GWR’s step and gap assessment and mitigation policy, which is based on the relevant national technical rules. This non-compliance reflects the vertical stepping heights for particular doorways, out of the 10 doorways on the unit, for platforms at stations served by the proposed service, as follows:

• West Ealing platform 5, where 6 doorway positions have a vertical step greater than 230mm
• Drayton Green platform 1, where 1 doorway position has a vertical step very marginally greater than 230mm
• Castle Bar Park platform 1, where all doorway positions have a vertical step greater than 230mm
• Castle Bar Park platform 2, where all doorway positions have a vertical step greater than 230mm
• South Greenford platform 1, where 8 doorway positions have a vertical step greater than 230mm

These vertical step dimensions are similar to the Class 165 trains currently in service on this route. The Class 165 units also have a dispensation against the equivalent sections in the former PRM TSI (section 4.2.2.12.2 (paras 2-4) and section 4.2.2.12.1) (PDF, 100KB).

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

The views of disabled passengers regarding the introduction of BEMU 230001 on the West Ealing to Greenford service have been sought via the GWR Accessibility Panel. This panel consists of various disabled customers and disability groups that help advise GWR on future projects and initiatives we introduce.

The panel meets monthly and has a focus on ensuring any new projects are designed to incorporate all passengers despite the barriers which disabled people face. The meeting at which the Fast Charge Trial was discussed took place on 27 February 2025. No specific concerns regarding ACC NTSN compliance were raised.

Measures to enable disabled people to use the vehicles

‘Mind the Step’ is stencilled in yellow on the platform surface where required, an on-board wheelchair ramp is available to bridge the gap, and assistance is available if summoned in advance. The on-board wheelchair ramp has been assessed at each platform on the route to ensure that, when deployed, it will be at the correct angle, which is a maximum slope of 18% (10.2°).

A review of accident reports at stations on the West Ealing to Greenford route indicated that there have been no accidents at the platform train interface. When unit 230001 is placed into passenger service, customer feedback will be monitored and this will provide additional operational, real-life experience.

Period for which dispensation to be in force

GWR is seeking dispensation to be in force for the remaining life of the vehicles, without an expiry date.

How to respond

See the Ways to respond section of the consultation page on GOV.UK, to find out how you can respond to this consultation.

The consultation period began on Friday 26 September 2025 and will run until Friday 24 October 2025. Please ensure that your response reaches us before the closing date.

What will happen next

We will publish a summary of responses and the government response on the homepage for this consultation. Paper copies will be available on request.

If you have questions about this consultation, please contact:

Philip Hunt
Rail Vehicle Accessibility
Rail Passenger Services
Department for Transport
4th Floor, Great Minster House
33 Horseferry Road
London, SW1P 4DR

Freedom of information

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004.

If you want information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory code of practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence.

In view of this, it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the department.

Data protection

The Department for Transport are carrying out this consultation to collect views on Great Western Railway (GWR) seeking a dispensation the minimum accessibility requirements in the Accessibility National Technical Specification Notice.

Your personal data collected through this consultation is processed in line with our online forms, surveys and consultations privacy notice.

Your responses will be shared with GWR. Your name and contact details will be removed before the responses are shared.