Closed consultation

RVAR 2010 – application for accessibility standards exemption received from Docklands Light Railway (DLR)

Updated 7 August 2023

This application is structured into a background and 4 topic sections, each of which covers an area for which an exemption is sought. These are:

• platform gap
• door warble
• B2007 trains
• B92 trains

Full name of the applicant

Tom Page, DLR General Manager.

The address of the applicant

Docklands Light Railway
Castor Lane
Poplar
London E14 0BL

Background

The Docklands Light Railway (DLR) was built as an accessible railway that includes:

• lift or ramp access to all platforms
• level access at train doorways
• on-board wheelchair spaces
• audio and visual announcements

DLR has operated driverless trains since its opening in 1987. Each train has a passenger service agent (PSA), who can assist passengers – stations are not staffed except at 3 major or sub-surface stations.

Labels are displayed on the outside of the train, on both sides, to show passengers where to board to be near a wheelchair space and priority seating stickers throughout the trains indicate the locations of priority seats.

The current DLR fleet consists of 149 vehicles that include 55 B2007s built in 2008 and 94 vehicles collectively known as B92 that comprise:

• 23 B90s, built in 1991
• 47 B92s, built in 1993
• 24 B2Ks, built 2011

These vehicles are operated in both 2-vehicle and 3-vehicle train consists. The B90s and B92s pre-date the initial rail vehicle accessibility regulations (RVAR) introduced in 1998. A scheme to refurbish the B2007s is being scoped, for completion around December 2027.

A new fleet manufactured by Construcciones y Auxiliar de Ferrocarriles (CAF) will introduce a minimum of 54 x 5-car units, designated B23, into service from autumn 2023. These trains will meet the requirements except where there are strategic operational or infrastructure constraints that prevent full compliance.

The programme for the new fleet remains on schedule despite the pandemic and the current financial challenges that Transport for London (TfL) faces. These trains will replace the 94 B92 vehicles.

Exemption Orders made to date

To date, 5 RVAR Exemption Orders have been made, as shown in the published List-of-rvar-exemption-orders. They are the:

• 2008 Order, for B2007 handholds (expired 2009), boarding device (expired 2014) and door audible warning and illumination off before door closes, and internal passenger information system (PIS) (expired 2016)

• 2015 Order, for B2007 boarding device – platform horizontal and vertical gap – expires September 2025 except for certain stations expired 2017 or 2018

• 2016 Order amended the 2015 Order for Bank Platform 10 from 1 January 2017 to 1 January 2021

• 2018 Order, for B2007 door audible warning and illumination off before door closes, on the condition that a risk assessment be undertaken and reported by March 2019, and for B92 and B2007 internal PIS when stationary

• 2019 Order, for B92 and B2007 door audible warning and illuminated warning signals, handrail clearance, doorway lighting, and for B92 wheelchair-route, handrail diameter, priority seat and space – expires December 2024

Section 1: platform gap

Description of the rail vehicles to which the application relates

DLR B92 stock, vehicle numbers 001 to 016 and 022 to 99 (manufactured by Bombardier, brought into use in 1991).

DLR B2007 stock, vehicle numbers 101 to 155 (manufactured by Bombardier, brought into use in 2007).

DLR B23 stock, vehicle numbers 201 to 254 (manufactured by CAF, due to be brought into use in 2023).

Services provided

Passenger vehicles used on all routes on the DLR, specifically when wheelchairs are traversing the gap between the train and the platform.

The provisions of RVAR from which exemption is sought

Schedule 1, part 1 (general requirements):

(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.

(2) Sub-paragraph (1) does not apply where the gap between the edge of the door sill of the wheelchair-compatible doorway and the platform, or stop, is not more than 75mm measured horizontally and not more than 50mm measured vertically.

(3) No boarding device other than a lift or ramp may be used.

The technical, economic and operational reasons for the application

The issue of gaps between train and platform on the DLR is complex. While most door openings have always satisfactorily met the 75mm gap requirement, some have not due to a range of reasons including the original design in the 1980s. Platforms need to have sufficient clearance from passing vehicles up to speeds of 50 kilometres per hour (km/h). While it might seem a vehicle has sufficient clearance when it is stationary next to a platform, when it is travelling at speed, especially on a curve, the clearance reduces at a critical point of the vehicle meaning that the platform structure must be set further away from the track to ensure the risk of a train striking a platform is reduced.

Reducing the line speed through platforms to reduce clearance to the train and subsequently have smaller stepping distances would significantly affect the DLR timetable, so fewer trains per hour can operate around the network. Redesigning track and platforms to not have curves would cost multi-millions, require lengthy blockades and cause months of disruption to passengers to only achieve 20mm improvements in stepping distances.

The appendix ‘RVAR Stepping Distances Compliance Report’ (65001-DLR-PRM-TR000-REP-F-0003) has summarised the technical, economic and operational reasons for the application. This includes a demonstration of how DLR’s new fleet, the B23s, will improve stepping distances across the network and also DLR’s plan to reduce non-compliance by moving platform edges closer to the track to improve stepping distances where it does not increase the risk of a platform-train strike and is economically viable to do so.

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

DLR considers stations with non-compliant horizontal stepping distance to the level seen on DLR to have mitigating factors, which means the non-compliances have a negligible impact on the user’s safety and the ability of a disabled person to use the rail vehicle. The mitigating factors were discussed in detail in the appendix ‘RVAR Stepping Distances Compliance Report’ (65001-DLR-PRM-TR000-REP-F-0003) and are as follows:

• 100% compliant vertical stepping distances (all door positions have vertical stepping less than 30mm)

• positive wheelchair user feedback on the size of the largest DLR horizontal stepping distances

• DLR’s general management of the platform train interface (PTI) and the results of an assessment of DLR PTI incidents

• several platforms have compliant stepping distances at doorways adjacent to non-compliant doorways

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

DLR still considers there to be a benefit in improving its compliance with the Department for Transport’s (DfT’s) RVAR horizontal stepping distance target value of 75mm despite demonstrating that the present day having mitigating factors which mean the non-compliances are acceptably safe for passengers to use. The appendix ‘RVAR Stepping Distances Compliance Report’ (65001-DLR-PRM-TR000-REP-F-0003) has outlined DLR’s plan to practically reduce non-compliances to make the experience of boarding vehicles as smooth as possible for disabled passengers in the future. This report highlights statistically how DLR’s proposal will improve RVAR stepping distances in 5 stages and summarises DLR’s positive progression to increase RVAR compliance to date.

Similarly to DLR’s 2015 exemption order request, with respect to using manual boarding ramps, DLR does not believe they offer an appropriate interim or long-term solution. This is based on the infrastructure constraints, the intensity of the train service and DLR’s operational staffing model.

The user trial done in 2015 demonstrated that such mitigation is simply not required to make DLR trains accessible to wheelchair users. DLR differs from the National Rail network in that it has narrower platforms, and generally a higher density of users, which makes the use of ramps a greater hazard. DLR also has no station staff at 41 of its 45 stations and services have considerably shorter dwell times at the platform than National Rail services.

It is almost certain that the introduction of ramps would increase dwell time, as onboard staff would have to identify the requirement, locate and then deploy the ramp, delaying not only that train but also those behind it. Any increase in dwell times would have a significant impact on the overall service and would significantly impede DLR’s ability to safely meet customer demand on the network and, thereby, increase crowding. The policy change would also increase the risk to the existing onboard DLR staff who would manage the deployment of such a solution. The change would also significantly increase the risk and inconvenience to wheelchair users, who currently do not wait for such a device to be deployed when boarding or alighting DLR trains.

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

Firstly, the DLR seeks an exemption until 29 September 2025 for the B23 vehicles for the following platforms that are currently allowed to have 85mm stepping distances for the B2007 vehicles due to the 2015 exemption order:

• Royal Albert 1 and 2

• Prince Regent 1 and 2

• All Saints 1 and 2

• Westferry 1 and 2

• Beckton 1 and 2

• West Silvertown 2

• King George V 1 and 2

• West India Quay 2, 3 and 4

• Lewisham 5 and 6

• Pontoon Dock 2

• Mudchute 2

Note that for each of these platforms, there is only 1 out of the 2 B23 wheelchair-compatible doorways for each 5-car vehicle that is expected to be above 75mm (but below 85mm) prior to works being completed before September 2025 to reduce the stepping distances below 75mm. The other wheelchair-compatible doorway at these platforms are compliant and do not require the exemption. See the appendix ‘RVAR Stepping Distances Compliance Report’ (65001-DLR-PRM-TR000-REP-F-0003) for more details.

Secondly, the DLR seeks an exemption until 31 March 2035 for the following platforms where addressing the non-compliances is possible and resolvable:

• Canning Town 3 and 4

• Canary Wharf 4 and 5

• East India 1 and 2

• Poplar 4

• Limehouse 3 and 4

• Bow Church 1 and 2

• West Ham 3 and 4

As DLR intends to replace these platforms by March 2035, it has decided that it is more economical and efficient to wait for their replacement than replace or adjust them by the existing temporary exemption order expiry date of 29 September 2025.

These platforms apply to all fleets. Note that for each of these platforms, there is only 1 out of the 2 B23 wheel-compatible doorways for each train that is expected to be above 75mm (but below 85mm) prior to works being completed before March 2035 to reduce the stepping distances below 75mm. For the B2007s and B92s adjacent to each of these platforms, there are 2 or 3 doors out of the 6 B92/B2007 wheelchair-compatible doorways for each 3-car vehicle that is expected to be above 75mm (but below 85mm) prior to works being completed before March 2035 to reduce the stepping distances below 75mm. The other wheelchair-compatible doorways at these platforms are compliant and do not require the exemption. See the appendix ‘RVAR Stepping Distances Compliance Report’ (65001-DLR-PRM-TR000-REP-F-0003) for more details.

Thirdly, the DLR seeks an exemption until 31 March 2060 for the following platforms where addressing the non-compliances is not possible until the end of the platform’s life, in 2060, because they are Herring-Bau structures, which cannot be affordably or safely moved in their current state:

• Tower Gateway 1 and 2

• South Quay 1 and 2

• Crossharbour 1 and 2

• Deptford Bridge 1 and 2

• Blackwall 1 and 2

• East India 1 and 2

These platforms apply to all fleets. Note that for each of these platforms, there is only 1 out of the 2 B23 wheel-compatible doorways for each train that is expected to be above 75mm (but below 85mm) prior to works being completed before March 2060 to reduce the stepping distances below 75mm.

For the B2007s and B92s adjacent to each of these platforms, there are 2 or 3 doors out of the 6 B92/B2007 wheelchair-compatible doorways for each 3-car vehicle that is expected to be above 75mm (but below 85mm) prior to works being completed before March 2060 to reduce the stepping distances below 75mm. The other wheelchair-compatible doorways at these platforms are compliant and do not require the exemption. See the appendix ‘RVAR Stepping Distances Compliance Report’ (65001-DLR-PRM-TR000-REP-F-0003) for more details.

Lastly, the following platforms require a permanent exemption order for the B92, B2007 and B23 fleets due to the track curvature present at those platforms resulting in a heightened risk of a platform-to-train collision if the clearance is reduced enough to achieve 75mm stepping distances:

• Bank 10

• Canary Wharf 4 and 5

• Limehouse 3 and 4

• Westferry 2

• Poplar 2

• All Saints 1

• Bow Church 2

• Mudchute 1

• Island Gardens 2

• Greenwich 3 and 4

• Royal Victoria 1 and 2

• Custom House 3 and 4

• Gallions Reach 1

Note that for each of these platforms, there is only 1 out of the 2 B23 wheel-compatible doorways for each train that is expected to be above 75mm. For the B2007s and B92s adjacent to each of these platforms, there are 3 or 4 doors out of the 6 B92/B2007 wheelchair-compatible doorways for each 3-car vehicle that is expected to be above 75mm. The other wheelchair-compatible doorways at these platforms are compliant with the 75mm and do not require the exemption. See the appendix ‘RVAR Stepping Distances Compliance Report’ (65001-DLR-PRM-TR000-REP-F-0003) for more details.

Proposed timetable of action to render the rail vehicle compliant

The appendix ‘RVAR Stepping Distances Compliance Report’ (65001-DLR-PRM-TR000-REP-F-0003) has outlined DLR’s plan to practically reduce non-compliances to make the experience of boarding vehicles as smooth as possible for disabled passengers in the future. It has outlined the 5 stages to achieve this. They are:

Actions 1 and 2

Replacement or adjustment work can be undertaken on 24 platforms to address the existing B92/B2007 non-compliances and B23 non-compliances in time for the end of the existing temporary exemption order in September 2025 so that the platforms are compliant to 75mm. An amendment to the current exemption order to include the new B23 fleet will be required.

Action 1

The DLR has an ongoing platform replacement project where platform replacement prioritisation is dependent on factors that rank the requirement for the replacement of DLR’s 102 platforms. Those factors are:

• asset condition (coper, tactile and slab)

• footfall

• platform age and remaining asset life

• PTI incidents

• exposure to the elements and slip resistance testing results

• RVAR stepping distance compliance

• DLR’s 25-year asset investment plan budget

Out of the 20 platforms where work can be undertaken to address the non-compliances before September 2025, 6 are due to be replaced. Designs can be undertaken in-house and a contractor is already appointed to deliver the works. Delivery is estimated to be complete by September 2025. The 6 platforms are:

• Royal Albert 1 and 2

• Prince Regent 1 and 2

• All Saints 1 and 2

Action 2

The remaining 14 platforms are not deemed to have poor enough asset condition to require replacement until later than 2035. Therefore, DLR has decided to move the platform coper edges closer to the track instead of replacing coper assets. A design invitation to tender is due to be sent out by August 2023 with a separate delivery invitation to tender due to be sent out by August 2023 for delivery to be complete by September 2025. These platforms are:

• Westferry 1 and 2

• Beckton 1 and 2

• West Silvertown 2

• King George V 1 and 2

• West India Quay 2, 3 and 4

• Lewisham 5 and 6

• Pontoon Dock 2

• Mudchute 2

Action 3

There are 13 platforms with RVAR non-compliances that are resolvable. These are planned to require replacement before March 2035, so DLR has decided it is more economical and efficient to wait for their replacement than replace or adjust them by the existing temporary exemption order expiry date of 29 September 2025.

This action will require these platforms to be covered by a temporary exemption order which, with risk included, would expire by 31 March 2035.

These platforms are:

• Canning Town 3 and 4

• Canary Wharf 4 and 5

• East India 1 and 2

• Poplar 4

• Limehouse 3 and 4

• Bow Church 1 and 2

• West Ham 3 and 4

Action 4

A new temporary exemption order shall be required to last until the end of the asset life of each of the 12 platforms, as the existing Herring-Bau structures cannot be affordably or safely moved in their current state. These platforms would require an exemption lasting until 2060, as the asset life of the structure built in 2010 is 50 years.

These structures were designed in 2009 and built to 85mm stepping distances following the Mudchute platform to train collision, which was before the creation of the new Standard that enabled smaller clearances between vehicles and platforms. DLR does not believe replacing these platforms now would be cost-effective given their remaining asset life is 37 years with their stepping distances being only 10mm more than the allowable 75mm.

These platforms are:

• Tower Gateway 1 and 2

• South Quay 1 and 2

• Crossharbour 1 and 2

• Deptford Bridge 1 and 2

• Blackwall 1 and 2

• East India 1 and 2

Action 5

A permanent exemption order will be required at 19 platforms due to the track curvature present at those platforms resulting in a heightened risk of a platform-to-train collision if the clearance is reduced enough to achieve 75mm stepping distances. These platforms are:

• Bank 10

• Canary Wharf 4 and 5

• Limehouse 3 and 4

• Westferry 2

• Poplar 2

• All Saints 1

• Bow Church 2

• Mudchute 1

• Island Gardens 2

• Greenwich 3 and 4

• Royal Victoria 1 and 2

• Custom House 3 and 4

• Gallions Reach 1

The largest non-compliant platforms are All Saints 1, Limehouse 4, Mudchute 1 and Poplar 1, as these each have one B23 RVAR door with a horizontal stepping distance greater than 85mm.

Prior consultation with vehicle operator

Docklands Light Railway Limited (DLRL) is the owner and operator (through a franchisee) of the rail vehicles. Therefore, there are no consultation responses to report.

Section 2: door warble

Description of the rail vehicles to which the application relates

DLR B92 stock, vehicle numbers 001 to 016 and 022 to 99 (manufactured by Bombardier, brought into use in 1991).

DLR B2007 stock, vehicle numbers 101 to 155 (manufactured by Bombardier, brought into use in 2007).

DLR B23 stock, vehicle numbers 201 to 257 (manufactured by CAF, due to be brought into use in 2023).

Services provided by the vehicles

Passenger vehicle. Used on all routes on the DLR.

The provisions of RVAR from which exemption is sought

Schedule 1, part 1 (general requirements)

3(3) Subject to sub-paragraph 3(4), each passenger doorway in the side of a rail vehicle must be fitted with an audible warning device, which must emit warning sounds in accordance with subparagraph (5) inside and outside the vehicle in the proximity of each control device for the doorway or, if there is no such control device, adjacent to the doorway.

3(5) Subject to sub-paragraph 3(6), the audible warning device must— 3(5)(b) emit a different distinct sound to that required by paragraph 3(5)(a) and, where applicable, paragraph 1 of part 2 of this schedule, commencing not less than 3 seconds before the door starts to close.

4(2) When power-operated doors are closed by a member of the operator’s staff the illumination of each such control device must cease not less than 3 seconds before the doors start to close.

Passenger doorways on DLR vehicles are fitted with compliant audible warning devices. However, the sound emitted does not commence 3 seconds before the doors start to close. Instead, the sound is omitted as the doors start to close with 0 seconds delay.

The door opening pushbuttons at each doorway are illuminated when they are available to be used. The illumination ceases when the doors begin to close – 0 seconds delay.

The technical, economic and operational reasons for the application

The DLR has operated without a delay between the warning sound and the door closing since the railway was first opened in 1987. DLR has developed its operational procedures and training over the lifecycle of the railway and identified:

• an optimum dwell time of 10 seconds
• a passenger service agent (PSA) present on every train checking the PTI before closing the doors who can judge if additional dwell time is required or if any passengers are at risk of getting trapped by the doors
• a 0-second warble delay

2018 trial

The origin of the 3-second door chime requirement is unclear according to the London Underground research undertaken for its RVAR application. However, it is likely this came from when RVAR regulated both heavy and light rail. A change to this has been recognised in persons of reduced mobility (PRM) technical specifications for interoperability (TSI) having a different requirement for door closure duration, which is 2 seconds.

In July 2018, a weekend trial was conducted with a 3-second audible warning delay, in line with the requirement under RVAR. The intention of the trial was to validate the modelling work, which had predicted significant operational issues, and to assess the impact on safety and service reliability. The trial validated the modelling, showing that the:

• 3-second warning sound could not be accommodated in the existing timetable without significantly increasing journey times on some routes
• vehicle requirements increased to an unsustainable level

Platform observations carried out during the trials also recorded a significant increase in door incidents at the platform train interface.

A further weekend trial of a 1-second warning sound was conducted in September 2018. However, a different approach was taken to that used in the 3-second trial. Whereas the 3-second trial had run with an amended timetable (to minimise the disruption to passenger services), the 1-second trial ran with an unchanged timetable.

Therefore, with the 1-second trial, it was possible to assess whether the additional time could be absorbed by the existing timetable. The results showed that operational issues were still present and control room staff had to manually intervene in regulating the service on several occasions to prevent greater disruption and performance impact.

Ordinarily, trains run automatically and increasing the number of manual interventions is undesirable from a human factors standpoint. As with the 3-second trial, an increase in door incidents was recorded.

The full results of these trials are included in the report Door closure warning sounds on the Docklands Light Railway: Report on the modelling and live trials of 1, 2 and 3-second door closure warning sounds.

Operational concerns if introducing a door closure delay with audible warning

Prior to the trial, modelling was undertaken to see if it was possible to maintain the current service frequencies while inserting a warning sound. This raised significant concerns which were then validated by the trial in 2018, the 3-second warning sound model showed that journey times would increase by as much as 19% on some routes. These increases are largely due to the infrastructure constraints within which the DLR operates, including several crossovers, junctions in the central area and single-line sections on the north route to Stratford.

An increase in the door closing times will also reduce the available recovery time, meaning that when the service is trying to ‘catch up’ from regular incidents causing delays, such as passenger actions, faults and additional dwell time to assist passengers, it has less capability to do so. This in turn could result in increased pressure on the PSA, who will know that they are falling more and more behind schedule.

There are a number of timetable improvements planned in line with the availability of the new and expanded fleet. Those with accessibility and other needs are advantaged by improving frequency due to a better service available and reduced crowding on platforms and trains. Therefore, the additional fleet is better used to improve frequency rather than be used to mitigate an increased dwell time.

A timetable improvement (increasing train frequency on some routes) has already been introduced in September 2022 and there are further increases to timetable frequency planned until 2026, turning DLR into an even higher capacity railway. A focus on reducing crowding is beneficial for all passengers.

Crowding can be further exacerbated at any time by disruption on either the DLR or neighbouring transport operators, which increases the number of passengers using DLR services. Moreover, many of the areas connected by the DLR are undergoing redevelopment and new links are now provided to the Elizabeth line, which is bringing significantly more people to East London and more passengers to the DLR. Any reduction in capacity as a result of an extended door closure warning sound remains undesirable from a safety, accessibility and customer experience standpoint.

Equally, these frequency improvements mean that there is less available time in the headway to increase dwell for advance warnings of door closure, and shorter wait times, which is expected to reduce rushing and subsequent potential for accidents.

Timetable improvements will be completed in 2027 in line with the completion of the new trains project and it will, at this point, be possible to assess whether an increased warning tone can be accommodated in line with the available dwell time. It is anticipated that an increase to 3 seconds will have a very significant impact and to 1.75 seconds (in line with London Underground) will still have some impact on proposed frequencies and recovery time.

Safety concerns if introducing advanced door warnings

The decision as to when to close the doors on a DLR train is made by the PSA, of which there is one on every train. The primary means of closing doors is carried out from a door control panel (DCP), located adjacent to each passenger door. When working from a DCP, the PSA is able to close all the other doors on the train while keeping the door local to the DCP open, allowing the PSA to continue monitoring the platform train interface (PTI). PSAs are trained to close the doors only when it is safe to do so, for example, when the PTI is clear. This is a safety-critical activity.

Once the other doors are closed, the PSA can then close the local door. When all doors are detected by the train systems as correctly closed, the train can depart in automatic mode. It is important to note that there is no control button on the DCP for a PSA to use to reopen doors once set to close. In the case of a passenger rushing on hearing the door warble, the PSA would not be able to take action on observing this passenger’s actions. This is different from London Underground where the close command can be cancelled and the door reopened. Therefore, the provision of door controls overall on DLR trains is currently incompatible with a door closing delay.

Feedback from PSAs during the trial in 2018 highlighted a reduced level of control over the door closure procedure. When carrying out the procedure without a warning sound delay, PSAs felt in control because the doors reacted immediately to their pressing of the close other doors (COD) button once they had checked the PTI was clear. However, the introduction of the warning sound delay increases the risk of door incidents, as it adds a period of time during which passengers may arrive at the PTI and attempt to board the train.

Many DLR stations have staircases and escalators very close to platforms, meaning the status of the PTI can change quickly. It is possible for passengers to arrive at the platform, hear the warning sound, see the doors are still open and attempt to board the train all within a 3-second period whereas they cannot in a 0-second period. Therefore, the PSA cannot be sure that the PTI will be clear when the doors begin to close 3 seconds after having pressed the COD button.

Observations during the trials clearly showed passengers rushing for trains, having arrived on the platform after the warning sound had started.

Number of passengers struck or trapped by closing doors as they attempted to board trains

• 3-second trial weekend: 16 incidents (8 per day)

• 1-second trial weekend: 12 incidents (6 per day)

• non-trial weekend: 0 incidents per day

• average number of incidents per day (2022 P1 to P8): 0.2 incidents per day

It is clear that the number of passengers struck by the doors significantly increased during the trials on the DLR. An increase in door incidents was also recorded in a similar study on London Underground’s Victoria Line. There, the increase was attributed to the ‘hustle effect’, whereby more passengers rushed to board trains upon hearing a longer door closure warning sound, increasing the likelihood of them being struck by the closing doors.

DLR has around 7.6 million passenger journeys per period as of October 2022. Since April 2022, DLR has seen an average of 6.75 PTI incidents per period. This would equate to an average of 0.88 reported PTI incidents per 1 million passengers per period.

In comparison, London Underground has about 84 million passenger journeys per period as of October 2022 and reports an average of 90 PTI incidents per period. This would equate to an average of 1.06 reported PTI incidents per 1 million passengers per period.

While it is noted that the DLR reported incidents are slightly lower per passenger journey than London Underground, it is also noted that the DLR PSAs are on the trains among passengers and, therefore, well placed to observe and report incidents. The data indicates that the DLR has a good safety record and well-tested operational procedures.

It is understood that passenger expectations may change and also within the context of the DLR there is a lot of change with the new fleet and increased frequency of timetable. It is noted that there may be a benefit of aligning the DLR with London Underground and a 1.75-second door warning, though trials and data to date does not significantly support this. An exemption until 2028 is sought to allow the DLR to continue to monitor the constraints and benefits of introducing a warble in the changing environment.

Technical concerns

Though it is technically feasible to move to a 3-second door warning for the B2007 and B23 fleets, there are a number of significant challenges associated with moving to compliance.

The doors on the older B92 fleet are pneumatically driven, so adding a door closure warning sound on these vehicles would require retrofitting a new component at each doorway. The delay would then need to be set to the right time duration, again at each door individually. For the B92 fleet, this is highly intrusive work on a critical train asset, which is also time-consuming and deemed not to be good value given that these assets are end of life. This is an additional reason that the exemption until 2028 is requested to give opportunity to consider the warnings once the B92s have been removed from service.

On the B2007 fleet, the doors are electrically driven and software-controlled. While no physical modification is necessary to change the duration of the door closure warning sound, the software needs to be uploaded to each door individually which is time-consuming and, therefore, has a cost implication.

It should be noted that this process will be easier on the future B23 fleet as the doors will be software-controlled and it will be possible to adjust the warning sound duration on all train doors simultaneously. The B92 fleet will be removed from service by 2026 (estimated) and will be replaced with the newer B23 fleet. Note that the new B23 fleet will also introduce sensitive edge technology into the door system, which increases the likelihood of detecting a trap and drag incident.

It would cause passenger confusion to have inconsistency between fleets during operation and, therefore, DLR believes it is safer and better for performance for the new B23 fleet’s door closure warning sound to commence at the receipt of the door closure command and cease upon detection of the door being fully closed on introduction.

Economic concerns (constraint applicable to modifying end-of-life B92s)

DLRL and its operator, Keolis Amey Docklands (KAD), incurred significant costs during the modelling and trialling of door closure warning sounds (£456,000). There would be a further projected cost of £650,000, which would be incurred if the new door timer relay was required to be installed across the entirety of the B92 fleet.

If this was extended beyond 0 seconds there may also be additional costs for:

• staff costs: additional staff (PSAs) to operate the additional trains to maintain frequency

• passenger cost: lengthened journey times would cause a passenger disbenefit

In addition to these costs, it is important to note that the B92s only have between 3 to 4 years of asset life left before they are decommissioned. Any work undertaken on them now would provide minimal benefits to the customers due to the amount of time it would take to deliver any adjustment works.

Conclusion

The trial completed in 2018 concluded that the current operating model of door warnings was the safest for the DLR. Further to the trial, given the technical and economic constraints of adapting the B92 fleet and the short remaining life of the fleet, it is not believed to be good value to propose any change to the B92 fleet prior to retirement.

Therefore, a further timed exemption is proposed to allow retirement of the B92 fleet where it is technically very challenging and uneconomical to make changes. Beyond retirement of the B92s, introduction of the new fleet and timetable frequency improvements (all planned to achieve by 2027), DLR would propose to undertake:

• a review of operational data to analyse passenger behaviours and expectations
• performance impacts of changing the warning length within the changing landscape of the DLR

This review would be proposed to be completed by the end of 2028 and, therefore, the exemption is requested until December 2029 to allow for any changes to the fleet, if required, or submission of a further exemption.

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

Although the DLR is a completely step-free network, it is recognised that some passengers may require additional assistance to complete their journeys. This includes people with mobility and visual impairments, but also a range of other user groups including school parties and families with young children.

A PSA is present on every train and will always check the PTI before closing the doors. PSAs are trained to look out for the aforementioned user groups and allow them extra time to board and alight if necessary.

During the 3-second trial, a passenger questionnaire was conducted. It included a section on the impact of the warning sound on accessibility, but due to the small number of respondents who disclosed a disability, the results were largely inconclusive.

DLR’s engagement with local accessibility groups has shown that the warning sound is not a significant issue or priority for disabled users. The issue has been discussed with representatives from Real, an organisation that works to improve opportunities for disabled people in the London Borough of Tower Hamlets. As part of its ‘local voices’ project, Real continually monitors feedback from the local community on accessibility issues on the DLR. It reported that it has not received any feedback from any member regarding door closure warning sounds, or the lack thereof and, as such, does not perceive this as a barrier to the railway being accessible.

Moreover, Real recognises the operational and safety issues that introducing a warning sound may cause. DLRL has committed to continued engagement with such groups to monitor any developments surrounding this issue, and other accessibility-related issues. DLR carried out accessibility forums and conducted a survey in 2022 to 2023. As yet the door warning has not been raised as an accessibility issue.

The 2022 to 2023 TfL customer satisfaction survey focused on accessibility in question 2 and the following information, taken from customer feedback, may be considered relevant to this application:

• 17% of DLR customers report having an impairment, the most common type being mental health conditions

• 3% of DLRs customers have mobility impairments

• overall satisfaction of customers with mobility impairment is 79 out of 100. DLR customers as an entirety report 80 out of 100, demonstrating a comparable level of satisfaction

• from our customer complaints and forums reporting, we know that the main complaint for mobility impaired passengers is lift availability and size of lift

• DLR customers with impairments suggested prioritising improvements in frequency, cleanliness of trains, smoothness of journeys and assistance from staff

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

Every DLR train has a PSA on board. Due to the automation of the DLR, the PSAs are relatively free to move through the train, offer assistance and information to passengers as well as check tickets. They receive specific training in how to identify the needs of disabled passengers (and all vulnerable users) and provide assistance as required.

On the B2007 fleet, the doors have obstacle detection and will open 50mm and attempt to close a maximum of 3 times to enable an obstacle to be removed. Should the obstruction remain, the doors will fail preventing all door closed indications. The B92 door system delivers a reduced closing force during the final stage of closing. Both fleets have a type of ‘pushback’, which gives the opportunity to extract trapped objects. The B23 fleet will have obstacle detection and sensitive door edge technology across all the door systems.

If a passenger is trapped in a door or an obstruction occurs, the PSA presses re-enable other doors (ROD) from the DCP and makes a passenger announcement. All doors will re-enable, which allows them to be reopened by passengers. If passenger safety is compromised the PSA will go to the affected doors to assist.

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

This exemption is requested until December 2029 to allow for any changes to the fleet if required, or submission of a further exemption.

Fleet expected life:

• B92s – estimated the end of 2026

• B2007s – estimated the end of 2037 (refresh due by 2027)

• B23s – from 2023 to an estimated 2068

Proposed timetable of action to render the rail vehicle compliant

2024: B23s to be brought into service on a rolling programme.

2022 to 2027: a series of timetable improvements in line with additional rolling stock available.

2025 to 2026: B92s to be retired.

2027 to 2028: gathering of further PTI safety data, passenger consultation and operational modelling.

2028 to December 2029: either submission of a further exemption or amendments to fleet.

Prior consultation with vehicle operator

DLRL is the owner and operator (through a franchise) of the rail vehicles. Therefore, there are no consultation responses to report.

Section 3: B2007 trains

Description of the rail vehicles to which the application relates

DLR B2007 stock.

Vehicle numbers 101 to 155.

Brought into use between 2007 and 2009.

Services provided by the vehicles

Passenger vehicle. Used on all routes on the DLR.

The provisions of RVAR from which exemption is sought

Schedule 1, part 1, 10(4)(b) distance between handrails and other parts of vehicle

Description of provision: There must be not less than 45mm 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.

Schedule 1, part 2, 3 door edge lighting

Description of provision: at a passenger doorway in the side of a rail vehicle, the edge of the floor along the entrance must be illuminated by a light placed within or immediately adjacent to that edge.

The technical, economic and operational reasons for the application

Schedule 1, part 1, 10(4)(b) distance between handrails and other parts of vehicle

Where a vertical handrail is adjacent to a transverse seat, the gap between the handrail and the top of the seat-back is only 20mm. The parts of the vertical handrail that are above or below this specific junction have compliant clearances.

It is not possible to comply with this regulation without major modifications to the fleet, with redesigned panels and handrails, at a significant cost.

Schedule 1, part 2, 3: door edge lighting

There is no light illuminating the edge of the floor at the entrances to the vehicle in the manner described in the regulation.

It is not possible to comply with this regulation without the design and installation of specific lighting in the door areas. This would be a significant modification at significant cost.

DLR has identified an opportunity for this work to be carried out in the most cost-effective way possible as part of a larger scope of works planned to be carried out to the vehicles at their mid-life point. This work will not be completed by the time the existing exemption order expires.

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

Schedule 1, part 1, 10(4)(b) distance between handrails and other parts of vehicle

Passengers are unlikely to encounter difficulty using the affected handrails given the location of the non-compliance being at the lower end of the handrail, which is not a natural position for an adult user to hold. The non-compliance only affects a single hand position along the length of the affected handrails. There are higher and lower hand positions with compliant hand clearance.

Schedule 1, Part 2, 3: door edge lighting

The impact of not having specific lights illuminating the door edge is minimised by the provision of good ‘main’ saloon lighting and platform lighting. A multicoloured ‘warning’ strip at the edge of the door (compliant with RVAR regulations) is fitted and further mitigates the non-compliance under this regulation.

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

Schedule 1, part 1, 10(4)(b) distance between handrails and other parts of vehicle

No immediate further measures are proposed, the vehicles can continue to be used by disabled people.

Schedule 1, part 2, 3: door edge lighting

DLR plans to introduce door edge lighting (which will remove the non-compliance to Schedule 1, part 2, 3) by the end of 2027.

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

Schedule 1, part 1, 10(4)(b) distance between handrails and other parts of vehicle

Untimed exemption – until end of life of the fleet (estimated 2037)

Schedule 1, part 2, 3: door edge lighting

Exemption until end of December 2027.

DLR has an existing permanent exemption (order 2018) against paragraph 11(5) – passenger information. That exemption is still required and is unaffected by this application.

Proposed timetable of action to render the rail vehicle compliant

2024 to 2027: B2007 mid-life refurbishment project (includes the addition of door edge lighting).

Prior consultation with vehicle operator

DLRL is the owner and operator (through a franchise) of the rail vehicles. Therefore, there are no consultation responses to report.

Relevant appendices

None.

Section 4: B92 trains

Description of the rail vehicles to which the application relates

DLR B92 stock (including all B90, B92, B2000 variants).

Vehicle numbers 001 to 016 and 022 to 099.

Brought into use between 1991 and 2001.

Services provided by the vehicles

Passenger vehicle. Used on all routes on the DLR.

The provisions of RVAR from which exemption is sought

Schedule 1, part 1, 6(5)(b) pathway to wheelchair spaces

Description of provision: Under RVAR 6(5)(b) the narrowest point on the pathway between a wheelchair-compatible doorway and a wheelchair space must be at least 850mm wide.

Schedule 1, part 1, 10(4)(b) distance between handrails and other parts of vehicle

Description of provision: there must be not less than 45mm 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.

Schedule 1, part 1, 11(8) height of letters displayed on the exterior/front visual display

Description of provision: in displays on the exterior of a rail vehicle the first letter of, and numbers used in visual announcements must not be less than 70mm high on displays mounted on the front of the vehicle and not less than 35mm high on displays mounted on the side of a rail vehicle. All letters and numbers must contrast with their background.

Schedule 1, part 2, 3 door edge lighting

Description of provision: at a passenger doorway in the side of a rail vehicle, the edge of the floor along the entrance must be illuminated by a light placed within or immediately adjacent to that edge.

The technical, economic and operational reasons for the application

Schedule 1, part 1, 6(5)(b) pathway to wheelchair spaces

The narrowest point on the pathway between the wheelchair-compatible doorway and the wheelchair space is 835mm wide, this is below the specified 850mm.

The seats opposite the wheelchair space protrude slightly into the intended pathway. This is a ‘boxed-in’ seat with equipment located beneath the seat. It is not economically or technically viable to create the additional 15mm clearance.

Schedule 1, part 1, 10(4)(b) distance between handrails and other parts of vehicle

Where a vertical handrail is adjacent to a transverse seat, the gap between the handrail and the top of the seat-back is only 30mm. The parts of the vertical handrail that are above or below this specific junction have compliant clearances.

It is not possible to comply with this regulation without major modifications to the fleet, with redesigned panels and handrails, at a significant cost.

Schedule 1, part 1, 11(8) height of letters displayed on the exterior or front visual display

The height of the characters on the exterior front display is 62mm against the regulation height of at least 70mm. The regulation is met with respect to the exterior side displays.

It is not possible to increase the text size without modifying the vehicle and replacing the displays, at a significant cost.

Schedule 1, part 2, 3 door edge lighting

There is no light illuminating the edge of the floor at the entrances to the vehicle in the manner described in the regulation.

It is not possible to comply with this regulation without the design and installation of specific lighting in the door areas. This would be a significant modification that would not deliver good value for money and customer benefit for the remaining life of the fleet.

DLR has identified an opportunity for this work to be carried out in the most cost-effective way possible as part of a larger scope of works planned at the vehicles’ mid-life point. This work will not be completed by the time the existing exemption order expires.

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

Schedule 1, part 1, 6(5)(b) pathway to wheelchair spaces

The width of the pathway to the wheelchair space is 835mm instead of 850mm. This has negligible effect on a disabled person’s ability to gain access to the wheelchair space.

Schedule 1, part 1, 10(4)(b) distance between handrails and other parts of vehicle

Passengers are unlikely to encounter difficulty using the affected handrails given the location of the non-compliance being at the lower end of the handrail, which is not a natural position for an adult user to hold. The non-compliance only affects a single hand position along the length of the affected handrails. There are higher and lower hand positions with compliant hand clearance.

Schedule 1, part 1, 11(8) height of letters displayed on the exterior or front visual display

This non-compliance is considered to have negligible impact on DLR passengers. As well as being shown on the front and sides of the trains, the destination information is shown on the digital information displays on all platforms before the train arrives and while it is in the station.

Schedule 1, part 2, 3 door edge lighting

The impact of not having specific lights illuminating the door edge is minimised by the provision of good ‘main’ saloon lighting and platform lighting. A multicoloured ‘warning’ strip at the edge of the door (compliant with RVAR regulations) is fitted and further mitigates the non-compliance under this regulation.

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

No further measures are proposed, the vehicles can continue to be used by disabled people.

These vehicles will be replaced with new B23 stock. The new trains are currently in manufacture/testing phase and are due to be introduced in 2023. There will be a phased transition with gradually fewer and fewer B92 vehicles being in use. The final B92 is due to be removed from service in 2026.

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

For an indefinite period. In practice, the programme to remove the trains from service and replace them with new B23 trains means it is unlikely that any B92 will remain after the end of 2026. DLR has an existing permanent exemption (order 2018) against paragraph 11(5) – passenger information. That exemption is still required and is unaffected by this application.

Proposed timetable of action to render the rail vehicle compliant

Not applicable – a permanent exemption is sought.

Prior consultation with vehicle operator

DLRL is the owner and operator (through a franchise) of the rail vehicles. Therefore, there are no consultation responses to report.

Relevant appendices

None.

Respond to this consultation

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.

You can email railvehicleaccess@dft.gov.uk or write to:

Department for Transport
Rail Vehicle Accessibility
Rail Passenger Services
2nd Floor, Great Minster House
33 Horseferry Road
London SW1P 4DR