Open consultation

RVAR 2010 exemption: London Underground Waterloo & City line 1992 Tube stock

Published 4 June 2025

Full name of the applicant

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

Address of the applicant

London Underground Limited
5 Endeavour Square
London E20 1JN

Background

London Underground is upgrading its Waterloo & City line trains, which were introduced in 1993. The 20 vehicles of 1992 Tube stock (92TS) that operate the service are similar to the 680 Central line 92TS vehicles, but differ in certain technical particulars, which means that they can work only on the Waterloo & City line.

These 20 vehicles are included in the Central Line Improvement Programme (CLIP), which will improve reliability and increase the degree of compliance with the Rail Vehicle Accessibility (Non-Interoperable Rail System) Regulations 2010 (RVAR 2010).

This exemption request is similar to London Underground’s request in 2019, which resulted in the Rail Vehicle Accessibility (Non-Interoperable Rail System) (Waterloo & City Line) Exemption Order 2019 (the 2019 order). 

This came into force on 1 January 2020, expiring on 1 January 2025, and granted exemption from certain regulations in part 1 of schedule 1 to the RVAR 2010. This exemption application should be read in conjunction with London Underground’s applications for Central line trains and for Central line platforms.

Exemption orders made to date

To date, 1 RVAR exemption order has been made, as shown in the published List of RVAR exemption orders.  It is 2019 Order, for 1992 Tube Stock (Waterloo & City Line).

Exemption request summary

Exemption until 1 January 2032 (to the end of the CLIP programme) is requested from regulations in part 1 of schedule 1 to the RVAR 2010 indicated by the paragraph numbers below. These correspond to articles 3(a), 3(b), 3(i) and 3(k) of the Rail Vehicle Accessibility (Non-Interoperable Rail System) (London Underground Waterloo & City) Exemption Order 2019, as shown:

• paragraph 8(2): floor of the vestibule to a passenger doorway in the side of a rail vehicle contrasts with the adjoining floor (2019 order 3(a))
• paragraph 8(6): band of single colour at passenger doorway contrasting with adjoining floor (2019 order 3(b))
• paragraph 10(4)(d): passenger handrail fitted to contrast with adjacent parts of the rail vehicle (2019 order 3(i))
• paragraph 18(4): number of wheelchair spaces required (2019 order 3(k))

Indefinite exemption (for the life of the vehicles) is requested from the following RVAR part 1 paragraph numbers below. These correspond to articles 3(d), 3(f), 3(g), 3(h), 3(i), 3(j) and 3(l) of the 2019 order:

• paragraph 10(1)(a): positions of handrails close to passenger doorways (2019 order 3(d))
• paragraph 10(6)(c): not less than 35 millimetres’ clearance between any part of the handrail and any other part of the rail vehicle (2019 order 3(f))
• paragraph 11(1), (5), (15): requirement to use a public address system fitted inside an exempt vehicle to announce the next stop (2019 order 3(g), (h), (i))
• paragraph 13(3): height of the priority seat’s base not less than 410 millimetres above the floor level (2019 order 3(j))
• paragraph 20(10) (a) Position of handrail protruding from the ceiling into a wheelchair space (2019 order 3(l))

Waterloo & City line vehicles

Description of the rail vehicles to which the application relates

The Waterloo & City line vehicle fleet, the 1992 Tube stock (92TS), was introduced from July 1993. 

Waterloo & City line 1992 Tube stock – vehicle numbers:

Class number: 1992 Tube stock

Manufacturer: ABB Transportation, Derby, United Kingdom

Fleet formation: 5 trains consisting of 10 2-car units, 2 of which are coupled together to form a 4-car train.

Waterloo & City trains are formed from:

• driving motor cars: 10 vehicles numbered 65501 – 65510

• non-driving motor cars: 10 vehicles numbered 67501 – 67510

Total number of vehicles is 20.

Services provided

The 20 92TS vehicles currently operate only on the Waterloo & City line, which runs from Waterloo station to Bank station, Mondays to Fridays only.

Normal services are provided at these times:

Waterloo to Bank

• weekday first train: 06:06
• weekday last train: 00:26

Bank to Waterloo

• weekday first train: 06:00
• weekday last train: 23:50

No services run on Saturdays and Sundays.

Exemption provisions of RVAR

The application seeks exemption from the Rail Vehicles Accessibility (Non-Interoperable Rail System) Regulations (RVAR) 2010 schedule 1, part 1 (general requirements) as follows:

8(2) Subject to sub-paragraphs (3) and (5), the floor of a vestibule to a passenger doorway in the side of a rail vehicle must contrast with the adjoining floor of the passenger saloon of the vehicle.

8(6) At a passenger doorway in the side of a rail vehicle the floor must have a band of single colour running parallel with the full width of the entrance:

• (a) not less than 50 millimetres and not more than 100 millimetres wide;
• (b) the edge of which furthest from the entrance must not be more than 100 millimetres from the edge of the floor at the entrance; and
• (c) which contrasts with the adjoining floor surface

10(1) Subject to sub-paragraphs (2) and (3), a handrail must be fitted in the following positions:

• (a) in every rail vehicle, on the inside as close as practicable to, and on either side of, the passenger doorways in the side of the vehicle, extending vertically from a point not more than 700 millimetres above the floor to a point not less than 1200 millimetres above the floor.

10(4) Subject to sub-paragraphs (5) and (6), any passenger handrail fitted in or to a rail vehicle must comply with the following requirements:

• (d) it must contrast with the parts of the rail vehicle adjacent to that handrail.

10(6) The requirements referred to in sub-paragraph (5) are that:

• (c) there must be not less than 40 millimetres clearance for a passenger’s hand between any part of the handrail and any other part of the rail vehicle, excluding the mountings of the handrail to the vehicle;

11(1) The interior of a rail vehicle must be fitted with a public address system for audible and visual announcements.

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.

11(15) A word on a display must not be written in capital letters only.

13(3) Each priority seat, and the space available to its user, must comply with the specifications shown in diagram C1 and in either diagram C2, C3 or C4 in schedule 2.

18(4) Where a train consists of the number of rail vehicles shown in a row of column A of the following table that train must have at least the number of wheelchair spaces shown in column B of the table set out below paragraph 18(4).

20(10) If a handrail is to be fitted to the ceiling of a rail vehicle, it may protrude into a wheelchair space provided that:

• (a) subject to sub-paragraph (11), it must not do so by more than 250 millimetres measured from the passenger gangway side of that space - (11) In its application to a narrow width vehicle, sub-paragraph (10)(a) has effect as if for 250 millimetres there were substituted 400 millimetres.

Technical, economic and operational reasons for the application

The Waterloo & City passenger fleet 1992 Tube stock (92TS) was introduced from July 1993. The 20 rail vehicles in service on the Waterloo & City line are similar to the 680 vehicles on the Central line, for which an exemption application is being made concurrently with this application. They differ in certain technical particulars, however, which means that they can work only on the Waterloo & City line.

In 2015, the 92TS were all scheduled to be replaced as part of the Deep Tube Upgrade Programme (DTUP) by 2035. With the significant reduction in government grant funding for the cost of operating London’s transport network and the forecasted revenue, a consequence of the wholesale business review of costs means that only Piccadilly line fleet replacement could be affordable. Other fleets including Waterloo & City line fleet was later included together with Central line as contractual options in the supply agreement with Siemens for new trains.

Given that there are no immediate plans for a new fleet, Transport for London (TfL) is undertaking a major programme, CLIP, which includes refurbishing of the existing Waterloo & City line rail vehicles into a RVAR compliant fleet. It includes:

• the installation of perch seat and pushchair priority area
• a floor covering patch to fill the floor area revealed by the installation of the wheelchair area, using the same type flooring as currently installed
• ’direction of travel’ stickers

The upgrade programme commenced works in 2018 to 2019, at which point completion in 2023 to 2024 was anticipated. Progress was impacted by the coronavirus pandemic, supply chain issues and technical problems since 2020. Due to the recent Central line service decline, a re-sequencing of all Waterloo & City line works including heavy overhaul is necessary to prioritise repairs on the Central line trains and recover passenger service as soon as possible. The rephasing is needed because the works on the Central and Waterloo & City line rail vehicles are delivered by the limited resources constrained by funding. 

As well as technical differences compared with the Central line vehicles, the Waterloo & City upgrade scope is different, and does not require work on the electronic and traction systems. This therefore requires a different technical solution for the passenger information system and emergency alarm, resulting in London Underground seeking an exemption from paragraph (11) (passenger information system) sub paragraphs (1), (5), and (13). London Underground also needs to undertake overhaul activities prior to other modifications to continue a safe service. 

Funding uncertainty remains but despite this challenge, the CLIP programme is expected to complete by 2031 to 2032.  This is in part because London Underground value accessibility improvements and has prioritised CLIP amongst other investments in the 2024 business plan.  The programme is fully resourced and set up at Acton Works, with Central line trains lined up for production and at Waterloo East Depot for the Waterloo & City line trains.

All the above challenges meant that the Waterloo & City line has been unable to meet the RVAR compliance by the 1 January 2025 exemption expiry date of the 2019 order for the clauses listed in above in Exemption provisions of RVAR.  

Exemption of the features included in the Waterloo & City RVAR modifications is therefore needed until 1 January 2032 for the following: 

8(2) Subject to sub-paragraphs (3) and (5), the floor of a vestibule to a passenger doorway in the side of a rail vehicle must contrast with the adjoining floor of the passenger saloon of the vehicle.

8(6) At a passenger doorway in the side of a rail vehicle the floor must have a band of single colour running parallel with the full width of the entrance:

• (a) not less than 50 millimetres and not more than 100 millimetres wide;
• (b) the edge of which furthest from the entrance must not be more than 100 millimetres from the edge of the floor at the entrance; and
• (c) which contrasts with the adjoining floor surface

10(4) Subject to sub-paragraphs (5) and (6), any passenger handrail fitted in or to a rail vehicle must comply with the following requirements:

• (d) it must contrast with the parts of the rail vehicle adjacent to that handrail

18(4) Where a train consists of the number of rail vehicles shown in a row of column A of the following table that train must have at least the number of wheelchair spaces shown in column B of the table set out below paragraph 18(4).

In addition to the above, London Underground also seeks indefinite exemption for non-compliant features (10(1)(a), 10(6)(c), 11((1), (5), and (15)), 13(3), 20(10)(a), which are needed for the life of the vehicle. This is because a replacement plan for a new-build (compliant) fleet is not anticipated prior to completion of the CLIP given TfL’s financial situation.

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

London Underground does not believe that an extension period for which the current non-compliances remain before being removed will cause any worse detriment to the ability of disabled persons to use the rail vehicles. 

To date, the 92TS vehicle is the least accessible fleet across the London Underground network. It currently lacks:

• wheelchair bays with height-adjusted emergency alarms
• passenger information system (PIS) in the saloon car
• single-band colour doorsills
• colour-contrast handrails and flooring  

London Underground believes that CLIP will bring significant improvements for our disabled customers. The scope for Waterloo & City vehicles includes:

• wheelchair bays
• single-band colour doorsills
• colour-contrast handrails and flooring
• better lighting using LEDs

The effects on passengers of each non-compliance are indicated below.

Paragraph 10(1)(a): handrails in doorways

The handrails adjacent to the 92TS rail vehicle doorways comply with RVAR. However, the usable height is between 660mm and 1135mm from floor height. The total measurement of the handrail as fitted to the 92TS is between 610mm and 1360mm high. RVAR states that a handrail must be between 700mm and 1200mm from floor height.

London Underground understands that the usable height does not consider the radius of the handrails at both ends owed to the curvature of the car body.

While it would be possible to replace the handrail in all door positions, London Underground believes that a redesign of the handrails and methods to fit them onto the narrow-width vehicle would not provide good value when weighed up against the limited benefit that this circa 100mm difference would bring to customers.

Paragraph 10(6)(c): handrail in a narrow width vehicle

Owing to the dimensions of the 92TS vehicles, an ovular handrail was fitted above the doorways. This allows for significantly more space to hold on when the vehicle is moving than if they were not fitted. It is assumed that at the time of construction, this profile was chosen so as not to impede on the space above the doorways which may have led to a risk of a person striking their head whilst boarding or alighting the vehicle. The current handrail follows the shape of the interior bodywork of the rail vehicle which would have had a protrusion if the handrail had a circular profile.

Although the current handrail is compliant in size with RVAR, the clearance between the top of the handrail and the bodywork is 35mm.  This falls outside the required 40mm. To comply with this requirement, the handrail would need to be lowered and this would introduce a hazard in the already restricted head height above the door. As such, London Underground cannot recommend adjusting the handrails.

London Underground also believes that there is little benefit provided by moving the handrail 5mm and any work which could take place to adjust the location of the handrails would also represent little or no value to customers. This was previously exempted in the 2019 order as it is not thought that there would be noticeable passenger benefit for the modification cost.

Paragraph 11(1), (5), and (15): passenger information

London Underground is committed to providing sufficient timely, accurate and accessible customer information to enable our customers to travel confidently, make informed decisions and to minimise the impact of disruption. 

As the Waterloo & City line serves only 2 stations, an audio-only information system in the rail vehicle for announcements of the starting and destinating or next station journey information is available. The external destination display at the front of the driving car also informs disabled persons of the travel direction. Inside the rail vehicle, there are maps and travel direction stickers in all carriages of the 2 stations.  This is because the next station can be ascertained from the destination, as routes are simple, London Underground believes that there is sufficient information for a 2-station short service with no intermediate stops.  

An early TfL engineering assessment concluded that the Waterloo & City line rail vehicles require a bespoke design different from the Central line (92TS). There is a high possibility that the design is complex and costly due to the limits of the original train electronic systems without the same upgrades planned for Central line fleet. The installation of an audible and visual information system in relation to announcing the 2 stations are likely to be protracted and unaffordable. This expenditure estimated to be £5.6 million would disproportionately outweigh the benefits of providing information available in the station.  

Instead, visual display of the destination station will be in the form of a label inside the vehicle to indicate the next station. See figure 1. Existing audio-only public address system will continue to inform service disruption in the rail vehicles and stations. A permanent exemption is therefore being sought that would allow the use of static information and audible passenger announcement inside the saloon car whilst the train is stationary at a platform.

Figure 1: static passenger information

Paragraph 13(3): heights of priority seats

The priority seats in the 92TS rail vehicles are the same height as the rest of the seats in the saloon. This height is 410mm which is 20mm below the minimum RVAR stipulated height of 430mm. It would be technically possible to raise the seat height. However, London Underground is concerned that raising only one seat would have aesthetic disadvantages.

Though it is possible to raise the seat height across the whole fleet, it is deemed on economic ground there was little benefit to raising the seat height. It was accepted in the previous exemption request that on economic ground, there was little benefit to raising the seat height. A user in the priority seat is unlikely to be impacted by the seat height being 20mm lower than required in the regulation. All priority seating is next to a handrail which can be used to aid standing and sitting.

Paragraph 20(10)(a): wheelchair space handrails

London Underground is seeking a permanent exemption that would allow the overhead handrail to extend 446mm only into the wheelchair space. This is because the wheelchair space is being retrofitted to the rail vehicles which was initially built before RVAR was introduced. London Underground needed to adjust the overhead handrails in the wheelchair area safely to accommodate the standing users.  

The wheelchair bay area is located between 2 double-leaf doors in car number 2. Existing seat bays are removed to create the area; and this allows more space for standing passengers closer to the carriage side. Only the overhead handrails retained for standing passengers such as carers of wheelchair users and other users are modified.

TfL human factors engineering assessment concluded that the original 405mm position presented risk of head impact of standing passengers represented by 45% of male population and 2% female population.  By adjusting to the new position, the risk is reduced to 20% of male population and 0.2% female population. The new position will result in a 446mm protrusion from the edge of the gangway side of the wheelchair space.  The vertical handrail between the 2 wheelchair bays and the doorway handrails are retained as an alternative support. See figure 2. This is a non-compliance to RVAR requirements 20(10) as shown in the diagram.

Figure 2: diagram of wheelchair bay area

Proposed measures to enable a disable person to use the rail vehicle

London Underground has modified one vehicle of each Waterloo & City train to fit 2 adjacent multi-functional areas. See figure 3.  These areas will be modified further to provide 2 wheelchair spaces, when an RVAR-compliant accessible-height emergency alarm for each space is fitted.

Figure 3: wheelchair bay area on the Waterloo & City line rail vehicle

As the design and modifications mature, London Underground needs to adjust the overhead handrails in the wheelchair area safely to accommodate all users. The wheelchair bay area is located between 2 double-leaf doors in car number 2. Existing seat bays are removed to create the area and this allows more space for standing passengers closer to the carriage side. As such, the overhead handrails are retained for standing passengers such as carers of wheelchair users and other users when the space is free.   

A user in the priority seat is unlikely to be impacted by the seat height being 20mm lower than required in the regulation. All priority seating is next to a handrail which can be used to aid standing and sitting.

London Underground also believes that the condition of the 92TS fleet needs to be addressed in parallel with the accessibility modifications. This refers to the overhauling of the Waterloo & City line vehicles to improve their current service performance levels.  These works will improve service reliability and relieve crowding to make the journeys easier for our disabled customers. 

London Underground uses a wide-ranging approach to assist disabled persons to use the Waterloo & City line rail vehicles. We engaged with local stakeholder groups 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 have 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
• and assisted transport services (door-to-door) such as Dial-a-Ride

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.

London Underground has sought to minimise the effect of these exemptions on disabled peoples’ ability to travel on the Waterloo & City line vehicles as set out above.  Continuous engagement with our wider TfL customer experience and stakeholder relationship teams has been had to communicate the work progress to our user groups.  

Information on accessibility modifications for disabled users is also featured on different media from railway publications, social networks, and news broadcast. London Underground has continuously engaged with our wider TfL customer experience and stakeholder relationship teams on CLIP progress and the requested exemptions.

Requested exemption period

In summary, London Underground seeks exemption for the Waterloo & City line 92TS for the following:

Exemption until 1 January 2032 (when the CLIP programme ends) from RVAR regulations 8(2), 8(6)(a), (b) and (c), 10(4)(d), and 18(4) (corresponding to articles 3(a), 3(b), 3(d), and 3(i) of the 2019 order).

Permanent exemptions from RVAR regulations 10(1), 10(6), 11(1), (5), (15), 13(3), and 20(10) for the life of the vehicles due to the issues with compliance as set out above (corresponding to articles 3(c), 3(e), 3(f), 3(g), 3(h) and 3(j) of the 2019 order).

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.