Closed consultation

RVAR 2010 exemption: Chiltern Railways passenger information system

Published 3 December 2024

Exemption request by Chiltern Railways concerning the passenger information system (PIS) on its class 165 and class 168 units

Full name of applicant

Tim Sayer, Engineering and Safety Director, Chiltern Railways

Applicant address

Marylebone Station
Melcombe Place
London
NW1 6JJ

Exemption request

Vehicles the application refers to

Chiltern Railways seeks exemption for the non-compliance of the passenger information system on its 67 class 165 and class 168 units, totalling 174 vehicles, listed below:

Vehicle numbers

Class 165: 39 units, 89 vehicles

• unit 165001: vehicles 58801 and 58834
• unit 165002: vehicles 58802 and 58835
• unit 165003: vehicles 58803 and 58836
• unit 165004: vehicles 58804 and 58837
• unit 165005: vehicles 58805 and 58838
• unit 165006: vehicles 58806 and 58839
• unit 165007: vehicles 58807 and 58840
• unit 165008: vehicles 58808 and 58841
• unit 165009: vehicles 58809 and 58842
• unit 165010: vehicles 58810 and 58843
• unit 165011: vehicles 58811 and 58844
• unit 165012: vehicles 58812 and 58845
• unit 165013: vehicles 58813 and 58846
• unit 165014: vehicles 58814 and 58847
• unit 165015: vehicles 58815 and 58848
• unit 165016: vehicles 58816 and 58849
• unit 165017: vehicles 58817 and 58850
• unit 165018: vehicles 58818 and 58851
• unit 165019: vehicles 58819 and 58852
• unit 165020: vehicles 58820 and 58853
• unit 165021: vehicles 58821 and 58854
• unit 165022: vehicles 58822 and 58855
• unit 165023: vehicles 58873 and 58867
• unit 165024: vehicles 58874 and 58868
• unit 165025: vehicles 58875 and 58869
• unit 165026: vehicles 58876 and 58870
• unit 165027: vehicles 58877 and 58871
• unit 165028: vehicles 58878 and 58872
• unit 165029: vehicles 58823, 55404 and 58856
• unit 165030: vehicles 58824, 55405 and 58857
• unit 165031: vehicles 58825, 55406 and 58858
• unit 165032: vehicles 58826, 55407 and 58859
• unit 165033: vehicles 58827, 55408 and 58860
• unit 165034: vehicles 58828, 55409 and 58861
• unit 165035: vehicles 58829, 55410 and 58862
• unit 165036: vehicles 58830, 55411 and 58863
• unit 165037: vehicles 58831, 55412 and 58864
• unit 165038: vehicles 58832, 55413 and 58865
• unit 165039: vehicles 58833, 55414 and 58866

Class 168/0: 5 units, 20 vehicles

• unit 168001: vehicles 58151, 58451, 58651 and 58251
• unit 168002: vehicles 58152, 58452, 58652 and 58252
• unit 168003: vehicles 58153, 58453, 58653 and 58253
• unit 168004: vehicles 58154, 58454, 58654 and 58254
• unit 168005: vehicles 58155, 58455, 58655 and 58255

Class 168/1: 8 units, 26 vehicles

• unit 168106: vehicles 58156, 58456, 58756 and 58256
• unit 168107: vehicles 58157, 58457, 58757 and 58257
• unit 168108: vehicles 58158, 58458, and 58258
• unit 168109: vehicles 58159, 58459, and 58259
• unit 168110: vehicles 58160, 58460, and 58260
• unit 168111: vehicles 58161, 58461, and 58261
• unit 168112: vehicles 58162, 58462, and 58262
• unit 168113: vehicles 58163, 58463, and 58263

Class 168/2: 6 units, 21 vehicles

• unit 168214: vehicles 58164, 58464 and 58264
• unit 168215: vehicles 58165, 58465, 58365 and 58265
• unit 168216: vehicles 58166, 58466, 58366 and 58266
• unit 168217: vehicles 58167, 58467, 58367 and 58267
• unit 168218: vehicles 58168, 58468, and 58268
• unit 168219: vehicles 58169, 58469, and 58269

Class 168/3: 9 units, 18 vehicles

• unit 168321: vehicles 79301 and 50301
• unit 168322: vehicles 79302 and 50302
• unit 168323: vehicles 79303 and 50303
• unit 168324: vehicles 79304 and 50304
• unit 168325: vehicles 79305 and 50305
• unit 168326: vehicles 79306 and 50306
• unit 168327: vehicles 79307 and 50307
• unit 168328: vehicles 79308 and 50308
• unit 168329: vehicles 79399 and 50399

Vehicle manufacturers

• class 165: BREL, York
• class 168: AdTranz, Derby

Vehicles brought into use

• class 165: 1991 to 1992
• class 168: 1998 to 2004

Services and routes operated by the vehicles

Chiltern Railways operate the class 165 and class 168 vehicles on services including:

• London Marylebone to Aylesbury Vale Parkway via Amersham
• London Marylebone to Stourbridge Junction via High Wycombe, Banbury and Birmingham Moor Street
• London Marylebone to Oxford via Bicester Village
• Princes Risborough to Aylesbury
• Leamington Spa to Stratford-upon-Avon

Provisions of RVAR 2010 for which application for exemption is requested

Paragraph 11 of schedule 1 of RVAR 2010 requires that the interior of a rail vehicle must be fitted with a public address system for visual announcements, and that the system must be used to announce the destination and next stop of the vehicle.

Chiltern Railways operates rail services where visual announcements are not made.

Paragraph 11 (1)

The interior of a rail vehicle must be fitted with a public address system for audible and visual announcements.

Paragraph 11 (5)

Whilst a rail vehicle is stationary at a station or stop any public address systems required to be fitted inside the vehicle, and on its exterior, must be used to announce the destination of the vehicle or, if it is following a circular route, the name or number of the route and, in the case of systems inside the vehicle only, to announce the next stop.

Paragraph 11 (6) 

Subject to sub-paragraph (7), the public address systems inside the rail vehicle must be used:

(a) to announce the next station, or stop, at which the vehicle will be stopping, not less than once during the period beginning 5 minutes before the vehicle is expected by the operator’s staff to stop at that station or stop;

(b) to announce any delay exceeding ten minutes to the scheduled timing for that journey;

(c) to announce any diversions from the route shown in the published timetable for that journey; and

(d) to make emergency announcements.

Paragraph 11 (7) 

Sub-paragraph (6) (a) does not apply if the timetabled journey time between stations or stops is less than 2 minutes.

Non-compliance explanation

Chiltern Railways has operated class 165 and class 168 trains for over 20 years on its services.

These trains both use passenger information systems (PIS) originally supplied by Whiteley Electronics so that the 2 fleets can work together when coupled in multiple unit formations. The PIS visually and audibly announces the destination and next station over the course of a journey.

The class 168s were determined as compliant with RVAR 1998 at the time of train construction, as the PIS represented the ‘state of art’ at the time. The assessment confirmed that the train PIS was able to make compliant visual announcements but there was no requirement to assess how this would be achieved in all operational circumstances. It was not until 2010 that enforcement was put in place through the Office of Rail and Road (ORR) to ensure that visual announcements are made when the compliant rail vehicles are operated. The PIS was retrofitted to the class 165 fleet between 2001 to 2004 during a large refurbishment. The construction of the class 165 fleet pre-dates RVAR 1998.

At the start of their journey, the driver selects a route code that contains the destination and stopping pattern for the journey. The route codes are stored in a database in each cab and are compiled using special off-train database software. The database is then manually uploaded to each cab (134 in total). The database is limited in size to 999 route codes. This is more than adequate for the base train plan used on most days.

There are short-term changes to the train plan due to engineering works and special events, such as events at Wembley Stadium. This results in changes to stopping patterns and destinations. It is impractical to generate a new database and upload it to each cab for these short-term changes. Therefore, it is not always possible to display the correct destination and stopping pattern. Drivers have the ability to make audio announcements for passengers reliant on audio announcements but there is no way in the PIS system for drivers to make changes to the visual announcements.

There are a number of options for resolution of the non-compliance. Each of these are considered in turn below.

Modification of the existing PIS

The existing system was designed in the late 1990s and reflects the technology of that time. The expertise to develop it to add in real-time train information downloading is incompatible with this technology. Realistically, it is better and easier to replace the entire system to achieve full compliance.

Installation of new compliant PIS

Chiltern Railways is funded through its national rail contract by DfT. DfT decides on which rolling stock investments to progress either through capex funding or lease charges.

Chiltern Railways has previously estimated that the cost of fleet replacement of the existing PIS with a modern PIS with real-time down loading of stopping patterns as £6.5 million. DfT has not agreed to fund this investment either directly or through lease charges when previously requested and therefore Chiltern Railways is unable to achieve compliance through PIS replacement.

Not altering stopping patterns or destinations

Chiltern Railways could adopt a policy of not altering stopping patterns for special events and only using pre-programmed stopping patterns in the event of engineering works. This would further limit the range of options available to passengers to get to special events (such as Wembley Stadium) and increase the number of bus replacement services in the event of engineering works. Neither of these outcomes are advantageous to customers (including passengers of reduced mobility) and are not in the best interest of the rail users.

Create a team to update and roll out PIS database changes in near real-time

Chiltern Railways could create a team to update and roll out changes to the PIS database in near real time. This team of around 5 people would prepare data base updates in conjunction with the train planners and then apply them across the fleet 24 to 48 hours in advance. This would require a team of 4 to 5 people at an annual cost of £280,000 to £350,000 but still would not achieve full compliance as changes to stopping patterns made on the day due to disruption would not be reflected in the visual announcements, and a team of 4 to 5 people is unlikely to achieve 100% roll out of a new database in 24 hours.

Chiltern Railways has operated these fleets for over 20 years. We have reviewed our customer complaints since December 2022 when we started to categorise complaints. We had 6 complaints regarding incorrect visual announcements on trains but none were due to this cause. They were caused by either a driver entering an incorrect route code or a defect with the PIS system. The platform-based customer information system (CIS) has real-time stopping patterns for trains on it, as it is fed with live information from the rail industry’s Darwin system. This can be used by passengers to confirm the destination and stopping pattern and any additional stops for special events.

Reasons for this application

Chiltern Railways was issued with an improvement notice by ORR on 19 February 2024 in relation to its inability to provide visual announcements on all its train services (improvement notice I-240219-02-GJT) and needs to remedy the non-compliance identified. The granting of this exemption would remedy the improvement notice by recognising that in some circumstances Chiltern Railways is unable to provide the correct destination and next stop visual announcements.

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

This non-compliance has existed for over 20 years and is caused by the technical limitations of the equipment installed at that time. There have been zero complaints relating to this cause in the last 18 months about this.

Chiltern Railways Accessibility Panel will be consulted about the non-compliant announcements as part of the process of seeking this exemption. This is not a subject that has been discussed or raised by them in the last 2 years.

Measures to enable disabled people to use the vehicles

Chiltern Railways is compliant with paragraph 11 of RVAR 2010 on over 90% of its passenger services that are operated in line with the base train plan. The exception is during:

• engineering works causing changes to stopping patterns and destination,
• special events resulting in changes to stopping patterns (e.g. Wembley Stadium events)
• short term changes due to disruption on the network

Chiltern Railways recognises that passengers are most in need of timely and accurate information during these exceptional events, and consequently ensure it provide real-time information on platform-based CIS screens, its website and through national rail data feeds. Assistance is provided at stations where the transfer to replacement bus services is required. Ticket offices are manned at the busiest stations as required by Chiltern Railways’ national rail contract where assistance can be obtained. Assisted travel is provided to customers requiring it by booking at least 2 hours in advance.

Period for which exemption to be in force

The period of exemption is requested to be for the remaining vehicle life. Current plans for new, compliant, trains are not yet firm but indicate that all the class 165 and class 168 units will be retired by 2040, although there is a good chance this could be extended depending on rolling stock requirements on the UK network.

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 3 December 2024 and will run until 7 January 2025. Please ensure that your response reaches us before the closing date.

What will happen next

A summary of responses, including the next steps, will be published within 3 months of the consultation closing on GOV.UK. Paper copies will be available on request.

If you have questions about this consultation please contact:

Philip Hunt
Rail Services Group
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. 

The department will process your personal data in accordance with the Data Protection Act and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties. 

Data protection 

DfT is carrying out this consultation to collect views on The Chiltern Railway Company Limited seeking an exemption from the minimum accessibility requirements in The Rail Vehicle Accessibility (Non-Interoperable Rail System) Regulations 2010. 

This consultation and the processing of personal data that it entails is necessary for the exercise of our functions as a government department. If your answers contain any information that allows you to be identified, DfT will, under data protection law, be the controller for this information.  

As part of this consultation, we’re asking for your name and email address. You do not have to give us this personal information but if you do we will only use it only for the purpose of asking follow-up questions. We may also ask whether you are responding on behalf of an organisation or yourself. If responding on behalf of an organisation, we may ask for the name of your organisation and your role in the organisation. You do not have to give us this personal information. If you do provide it, this allows us to ascertain your validity to the organisation when responding.  

Your responses will be shared with The Chiltern Railway Company Limited. Your name and contact details will be removed prior to that sharing taking place.  

Your personal data will be kept securely by DfT and anonymised within one year of DfT receiving the data. 

Further information 

For more information about your rights in relation to your personal data, how to complain or how to contact the DfT Data Protection Officer, view our personal information charter.

Consultation principles 

This consultation is being conducted in line with the government’s consultation principles. 

If you have any comments about the consultation process, contact: 

Consultation Co-ordinator
Department for Transport
Zone 1/29
Great Minster House
London SW1P 4DR

Email consultation@dft.gsi.gov.uk