Open consultation

RVAR 2010 exemption: London Underground Central line platforms

Published 4 June 2025

Full name of the applicant

Richard Jones, Director of Asset Performance Delivery, London Underground Limited

The address of the applicant

London Underground Limited
5 Endeavour Square
London E20 1JN

Background

London Underground is undertaking a Central Line Improvement Programme (CLIP), which will bring technical improvements to raise the reliability of the Central Line service, which is operated by the 1992 Tube stock (92TS). CLIP includes various accessibility enhancements, including provision of wheelchair spaces, to increase the degree of compliance of the 92TS with the Rail Vehicle Accessibility (Non-Interoperable Rail System) Regulations (RVAR) 2010 (RVAR 2010). 

At stations on other London Underground lines the platform humps bring the platform level with the wheelchair accessible doorways. However, the externally hung doors on the 92TS increase the gap between the doorway edge and the platform edge by 55mm when the doors are open. Consequently, the smallest gap possible between a 92TS vehicle doorway and a platform at the same level is 140mm, as in the 2019 consultation. This compares with the 75mm maximum (and 50mm maximum vertical step) at which RVAR 2010 requires the provision of a boarding ramp.

The application consists of this document, relating to the Central line platforms and a similar application document accompanying this one relating to the Central line trains and an application relating to the Waterloo & City line.

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 the Rail Vehicle Accessibility (Non-Interoperable Rail System) (Central Line 92 Tube Stock) Exemption Order 2019 (the 2019 order).

Exemption request summary

Exemption is requested from regulation 1 (1) in part 1 of schedule 1 to the RVAR 2010 for each of the Central line platforms as set out below, under the headings:

• platforms to which the application relates
• period for which the exemption order is requested

The Central line serves 49 stations (all stations in central London are underground) over 74 kilometres. It interchanges with other services at Bank, Ealing Broadway, Liverpool Street, Tottenham Court Road and Stratford stations for National Rail, London Overground, Docklands Light Rail and buses.

In 2019, London Underground was granted an exemption from the requirement to provide boarding devices when the 1992 Tube stock are stationary at specified platforms on the Central line, as listed in the schedule parts (1) and (2). This exemption will no longer be valid when step free access is provided from the specified station using the ‘Pimlico Principle’.

The Pimlico Principle approach was developed by London Underground with the Department for Transport (DfT) and the Disabled Persons Transport Advisory Committee (DPTAC) and was subsequently agreed in Parliament. This is based on a precedent 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 therefore allows platforms that do not fit into one of the 3 categories below to be exempt from providing level or step-free access between the train and platform.  

The 3 categories are:

1. A station that provides step-free access from street level to platform.

2. A station that is planned to provide step-free access from street level to platform.

3. A station that provides useful (and step-free) interchanges or is a terminus.

Platforms that do not fit into any of these categories (1 to 3) are labelled category 4 (referred to as ‘Pimlico Platforms’) and do not require wheelchair access between the train and the platform. For Central line, London Underground is seeking exemptions specific to schedule 1, part 1 (general Requirements), paragraph 1 (boarding devices at wheelchair-compatible doorways), under the Pimlico Principle at the 27 stations as there are no possible step free journeys listed in section 1 of this application:

• 1(1) Subject to sub-paragraph (2), when a wheelchair-compatible doorway in a rail vehicle is open at a platform at a station, or at a stop, a boarding device must be fitted by the operator between that doorway and the platform, or the stop, if a disabled person in a wheelchair wishes to use that doorway

This approach was developed during the Victoria Line upgrade (VLU) 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, Central, Jubilee, Piccadilly and Northern lines.

Since the 2019 order came into force, London Underground has made compliant the following station platforms listed in the schedule to the 2019 order:

• schedule list part 1: Liverpool Street, Marble Arch, and North Acton (Platform 1 only)
• schedule list part 2: Debden, Leytonstone, White City, and Woodford

Central line platforms

Platforms to which the application relates

Exemptions are sought in relation to non-compliant platforms at the following 27 Central line stations where the rail vehicles serve:

• Bank
• Bethnal Green
• Chancery Lane
• Chigwell
• East Acton
• Fairlop
• Gants Hill
• Grange Hill
• Hanger Lane
• Holland Park
• Holborn
• Queensway
• Leyton^{[footnote 1]}
• Lancaster Gate
• North Acton
• Northolt^{[footnote 1]}
• Notting Hill Gate
• Redbridge
• Oxford Circus
• Shepherd’s Bush
• Snaresbrook
• South Ruislip
• St. Paul’s
• Theydon Bois
• Wanstead
• West Acton
• West Ruislip

Services provided

Table 1: Eastbound services from Ealing Broadway and West Ruislip

Normal services are provided at these times.

Time of the week	First or last train	Eastbound services from Ealing Broadway	Eastbound services from West Ruislip
Weekday	First train	05:29	05:23
Weekday	Last train	23:55	23:53
Saturday	First train	05:29	05:23
Saturday	Last train	01:05[footnote 2]	23:53
Weekend	First train	05:15	06:41
Weekend	Last train	23:16[footnote 3]	22:58[footnote 3]

Table 2: Westbound services from Epping and Hainault

West-bound services can start from Epping and split after Buckhurst Hill to continue to Woodford or travel via Hainault to Leytonstone. All services joined at Leytonstone and run through central London all stations to North Acton, where the line splits again to travel to Ealing Broadway and West Ruislip.

Time of the week	First or last train	Westbound services from Epping	Westbound services from Hainault
Weekday	First train	05:10	04:50
Weekday	Last train	23:45	23:51
Saturday	First train	05:10	05:23
Saturday	Last train	01:33[footnote 4]	23:51
Weekend	First train	06:42	06:10
Weekend	Last train	22:42[footnote 5]	23:07[footnote 6]

The provisions of RVAR from which exemption is sought

The application seeks exemption from RVAR 2010 schedule 1, part 1 (general requirements) as follows:

• 1.(1) subject to sub-paragraph (2), when a wheelchair-compatible doorway in a rail vehicle is open at a platform at a station, or at a stop, a boarding device must be fitted by the operator between that doorway and the platform, or the stop, if a disabled person in a wheelchair wishes to use that doorway
• schedule 1, part 1 (general requirements): boarding devices at wheelchair-compatible doorways

The Central line passenger fleet (92TS) was introduced from April 1993. Among London Underground fleets, the Central line serves the second highest passenger numbers after Northern line and provides poorest reliability since 2015 to 2016. Main causes of poor reliability are the traction motors and obsolete electronic systems.  In 2015, they were scheduled to be replaced as part of the Deep Tube Upgrade Programme (DTUP) by 2035. However, due to economic challenges at that time, London Underground entered into contract with Siemens Mobility Limited, which is currently being used to replace the Piccadilly line fleet. Central line fleet was later included as contractual options in the supply agreement with Siemens for new trains.   

London Underground defines access where passengers can use lifts or ramps between the street and the platform or/and trains and so 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:

a) Maximum gap = 75mm.

b) Maximum step = 50mm.

c) This equates to 90mm on the diagonal.

Technical, economic and operational reasons for the application

London Underground is upgrading all 85 trains of 92 Tube stock that operate the Central Line service. When the upgrade programme commenced in 2018 to 2019, completion was anticipated in 2024 to 2025. The Central Line Exemption Order 2019 was made on this basis, with expiry date of 1 January 2025. As a consequence of Covid-19, supply chain issues, technical problems and funding uncertainty, the upgraded trains will be introduced progressively from 2025 to 2031.

Replacement with a fleet of compliant new-build vehicles is not anticipated in the next 10 years or more and as such, there is no plans to modify existing stations infrastructure such as platforms, platform nosing, and track beds. Only Leyton and Northolt stations on the Central line are progressed with funding certainty to be made fully accessible. With the technical and financial challenges, London Underground is formally requesting exemption for features regulated by the following RVAR paragraph number:

• Para 1(1) Boarding devices, Central Line platforms at: Bank, Bethnal Green, Chancery Lane, Chigwell, East Acton, Fairlop, Gants Hill, Grange Hill, Hanger Lane, Holland Park, Holborn, Queensway, Leyton, Lancaster Gate, North Acton, Northolt, Notting Hill Gate, Redbridge, Oxford Circus, Shepherd’s Bush, Snaresbrook, South Ruislip, St. Paul’s, Wanstead, West Acton, West Ruislip, and Theydon Bois. 

Platform and train level access between trains and platforms is not possible on Central line platforms (platform humps, nosing realignment, or track-raising) from the technical perspective. This is because Central line has some of the most severely curved platforms such as Bank station (Westbound).  

Besides the platform curvatures, the 92TS rail vehicle has an externally hung door arrangement with no outer sill plate. This means that once the doors are opened, the gap increases by 55mm to the inner sill plate. As the maximum gap requirement is 75mm, there is only 20mm left for vehicle movement and allowance for curvature after the door opens.This is considered impracticable even for straight and tighter tolerance on Central line platforms; and therefore, London Underground is unable to install platform humps on the platforms listed in this request.

Most Central line deep Tube platforms are constrained by the station orientation and space is restricted by existing infrastructure. These platforms interface with other lines, utilities and assets such as power, signals, and adjacent infrastructure such as tunnels. As such, it is economically unaffordable and highly disruptive to make deep underground stations step-free. Works are highly complex involving intrusive works, services and utilities diversions which will affect users in both the station and surroundings. 

London Underground’s solution for Central line is to provide a manual boarding ramp (MBR) where the step and gap between the rail vehicle and platform is greater than 50mm and 75mm respectively. Assessment to provide MBRs was then made on the ‘central section’ of the Central line between White City and Leytonstone inclusive. Central section platforms are generally more crowded and so the safety risks (such as trips and falls) are greater when using MBRs. 

Where there is an accessible interchange, such as to the Elizabeth line, MBRs are provided at Bond Street, Liverpool Street and Tottenham Court Road. Beyond this central section, MBRs were considered on quieter stations where there is step-free access and safe to do so, London Underground provided MBRs at locations in part 2 of the 2019 order – Debden, Leytonstone and Woodford stations.

With an increasing number of disabled customers having the confidence to use London Underground services, local operational staff highlighted several incidents relating to trains terminating early or reversing at certain stations. Disabled customers who may have been aboard these trains at accessible platforms would need to be assisted in alighting from the terminated train and then re-boarded onto the next through train. In these situations, where technically possible and safe, a ramp will be provided at terminating stations such as White City.

Where there are no possible step-free journeys from street to platform, London Underground is requesting for exemptions under the Pimlico Principle. The list for which exemptions are sought and under the relevant circumstances is outlined below.

Table 3: exemptions sought

Station	Reason exemption is sought
Bank	Highly complex and disruptive works to make step-free to a curved westbound platform
Bethnal Green	Highly complex and costly intervention with restrictions from Liverpool Street sidings.  No funding allocation to make station step-free
Chancery Lane	Major disruptions and high costs to remodel the underground station beneath existing buildings and traffic road
Chigwell	No funding allocation to make station step-free
East Acton	No funding allocation to rebuild surface station ticket hall and make step-free
Fairlop	No funding allocation to make station step-free
Gants Hill	Major disruptions and high costs to re-build station underneath roundabout and existing subways
Grange Hill	Complex and costly works to re-align curved platforms and make the station step-free
Hanger Lane	Complex to make station step-free requiring subway re-build to make compliant to access the station.
Holland Park	Constrained space to install lifts and make station step-free from lower passageway to platforms
Holborn	Major disruptions, highly complex and costly to remodel the underground station and inter-connecting Piccadilly line beneath existing buildings and traffic road network
Queensway	Constrained space to install lifts and make station step-free from lower passageway to platforms
Lancaster Gate	Constrained space to install lifts and make station step-free from lower passageway to platforms
North Acton	Station capacity upgrade and step-free access awaiting engineering designs and funding confirmation
Notting Hill Gate	Constrained space to install lifts and make station step free from street to platforms
Redbridge	Complex works involving remote access in an existing car park and Grade II listed building constraints. No funding allocation to make station step-free
Oxford Circus	Would need to be part of a major redevelopment scheme – highly complex and disruptive works to make Central line step free and interconnecting with the Bakerloo and Victoria lines.
Shepherd’s Bush	Challenging and disruptive works are restricted by utilities underneath Uxbridge Road and above the platforms.  No funding allocated to make station step-free.
Snaresbrook	No funding allocation to make station step-free and platform space constraints
South Ruislip	No funding allocation to make station step-free and interfaces with Network Rail structure are required
St Paul’s	Highly complex, costly and disruptive works to make step free; it is also likely to require Transport and Works Act powers
Wanstead	Studies found no practical solution nor funding allocation to make station step-free
West Acton	Complex works involving Grade II listed building constraints and no funding allocation to make station step-free
West Ruislip	No feasible solution identified and funding allocation to make station step-free
Theydon Bois	No funding allocation to make station step-free

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 peoples’ ability to travel. By using MBRs at key step-free stations, disabled persons will be able to reach parts of the Central line that will otherwise have no provision for customers with mobility impairments.

For example, Stratford station is in an open section and there are 3 Central line platforms – 3A, 3, and 5. Two of these (3A and 3) serve a single Central line track (westbound) for which the doors open on both sides. Platform 3A provides level access to customers to interchange with the other services – Elizabeth and Jubilee lines, as well as mainline rail, London Overground and Dockland Light Rail services to other destinations.

London Underground has also installed MBRs at the below locations as required in Section 3 (a) of schedule 1 of the previous 2019 exemption order.  These stations – excluding Debden and Woodford – are inaccessible from street to platforms for wheelchair users. Therefore, the boarding devices are for operational purposes in the event of unexpected terminations, or when passengers are taken ill for example, as advised by DPTAC in the 2019 RVAR exemption application consultation. 

These station platforms are:

• Barkingside
• Debden
• Leytonstone
• Liverpool Street
• Marble Arch
• North Acton
• Woodford

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

It is impractical to make all stations step-free on the line due to the constraints outlined above. TfL’s public transport system is an integrated network that offers alternative accessible options across London. Particularly in the central London area, the Central line connects to other Underground services and the Elizabeth line. There are also fully accessible buses free to all wheelchair users that connect to the Underground and rail network across London.

In addition to the above alternative travel choices, London Underground uses a varied approach to assist disabled persons to use the Central line rail vehicles. Local stakeholder groups have been engaged and they regarded readily available information such as live travel updates and alternative transport options as very important for their journey planning. In response, TfL has improved the journey planner and transport accessibility information for disabled persons to use our network. These include:

• online travel advice (guides, maps and journey planner such as step-free map and avoiding the stairs Tube guides)
• passenger assist service with National Rail services
• travelling with a guide dog
• assisted transport services (door-to-door), such as Dial-a-Ride

Our people are key to the above travel tools and services. TfL provides accessibility champions who have in-depth knowledge in the contact centres to ensure that the disabled persons are assisted. At step-free stations with MBRs, staff are trained to assist customers and deploy the boarding devices.  

Assistance is available on a ‘turn up and go’ basis meaning that delays to a journey are minimised as much as practical and do not need to be planned or booked in advance. This is enabled by real time travel information on the TfL Go App. Station staff will also check the disabled user’s planned step-free journey is free from disruption and if an alternative is needed due to service disruptions, they can arrange assistance.

At selected stations included in the Accessible Travel Policy (ATP), advanced booking is required to ensure a seamless transfer from rail to London Underground services. This service will be provided on Central line stations interchanging with London Overground, Elizabeth line and National Rail services at Greenford, South Ruislip, Stratford and West Ruislip. Soon, as part of our ATP, London Underground will be offering pre-booked luggage assistance at 30 stations interchanging with train operating companies (TOC).

On board the rail vehicles, the drivers have in-cab CCTV that relays pictures from multiple cameras so they can see the platform-train gap along the whole length of the platform even if crowded. Central line operators achieve the same visibility using multiple CCTV monitors on the platform, opposite the driving position, to ensure disabled users board and alight the train safely.

Customer experience and operations staff have been briefed on the new boarding and alighting positions of the Central line trains since late 2023. Bulletins distributed to the staff outlined the instructions when helping passengers use the Central line at every station. A label on the designated carriage helps staff to correctly deploy the ramp in the correct car as more refurbished rail vehicles are introduced into service. 

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. More 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, but 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 (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. Construction remains on schedule to start at Northolt and Leyton in early 2025, to make the stations accessible.

Looking at the financial constraints, Transport for London assessed buildability of step free access in terms of costs, risks, disruptions, and benefits. More than a third of Tube stations now provide step-free access, with the Mayor of London’s goal set at making 50% of Tube stations step-free by 2030. Progress will depend on deliverability and our funding position, with feasible schemes prioritised where there is third-party funding available as seen in the cases of Northolt and Leyton stations. 

Construction on a much-needed new, larger ticket hall, 2 lifts, 2 new staircases and an overbridge at Leyton station has started. This is possible only with financial support from the government and London Borough of Waltham Forest.

The period for which the exemption order is requested to be in force

London Underground requests exemption until 1 January 2032, by which time a view on the need to replace the Central line fleet will be considered. With the replacement fleet designs, the constraints at the platforms will potentially be removed.

Therefore, London Underground seeks an exemption order until 1 January 2032 against the following regulations:

• Para 1(1) Boarding devices, Central Line platforms at: Bank, Bethnal Green, Chancery Lane, Chigwell, East Acton, Fairlop, Gants Hill, Grange Hill, Hanger Lane, Holland Park, Holborn, Queensway, Lancaster Gate, North Acton, Notting Hill Gate, Redbridge, Oxford Circus, Shepherd’s Bush, Snaresbrook, South Ruislip, St. Paul’s, Wanstead, West Acton, West Ruislip, and Theydon Bois.

Specifically, London Underground is requesting exemptions for the following:

• Bank, platform 5
• Bethnal Green, platforms 1 and 2
• Chancery Lane, platforms 1 and 2
• Chigwell, platforms 1 and 2
• East Acton, platforms 1 and 2
• Fairlop, platforms 1 and 2
• Gants Hill, platforms 1 and 2
• Grange Hill, platforms 1 and 2
• Hanger Lane, platforms 1 and 3
• Holland Park, platforms 1 and 2
• Holborn, platforms 1 and 2
• Queensway, platforms 1 and 2
• Lancaster Gate, platforms 1 and 2
• North Acton, platforms 2 and 3
• Notting Hill Gate, platforms 3 and 4
• Redbridge, platforms 1 and 2
• Oxford Circus, platforms 1 and 2
• Shepherd’s Bush, platforms 1 and 2
• Snaresbrook, platforms 1 and 2
• South Ruislip, platforms 1 and 2
• St. Paul’s, platforms 1 and 2
• Theydon Bois, platform 1
• Wanstead, platforms 1 and 2
• West Acton, platforms 1 and 2
• West Ruislip, platforms 1 and 4

Additionally, London Underground seeks an exemption order until 1 January 2028 for the following station platforms:

• Leyton, platforms 1 and 2
• Northolt, platforms 1 and 2

Prior consultation with vehicle operator

London Underground is both owner and operator of the 92TS. Consequently, in this case the requirement for consultation with the vehicle operator is not relevant.

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 4 June 2025 and will run until 11:59pm on 2 July 2025. Please ensure that your response reaches us before the closing date.

1. Leyton and Northolt station platforms will be made step-free by 30 November 2025 and 31 December 2027 respectively, until which time a limited exemption is requested. ↩ ↩²

2. A Night Tube service operates between Ealing Broadway and Loughton/Hainault (via Newbury Park) overnight on Friday nights/Saturday mornings and Saturday nights/Sunday mornings. ↩

3. First and last train through-services from Ealing Broadway terminates at Hainault. All other last train services from Ealing Broadway will terminate at White City. Same applies to West Ruislip through-service to Epping.  All other later services will terminate at White City. For latest timetable information, please check the TfL website. ↩ ↩²

4. A Night Tube service operates between Loughton/Hainault (via Newbury Park) and Ealing Broadway overnight on Friday nights/Saturday mornings and Saturday nights/Sunday mornings. ↩

5. First and last train through-services from Epping through-service to West Ruislip.  All other later services will terminate at Loughton or Woodford. ↩

6. Hainault last through-service will terminate at Ealing Broadway with the later services interchanging at White City towards West Ruislip. ↩