Consultation outcome

RVAR 2010 – application for accessibility standards exemption

Updated 18 July 2023

This application form sets out the minimum required information in support of applications for exemption from the accessibility standards prescribed in the schedule to the Rail Vehicle Accessibility (Non-Interoperable Rail System) Regulations (RVAR) 2010 as prescribed by the Rail Vehicle Accessibility (Applications for Exemption Orders) Regulations 2010 SI 427/2010: Schedule 1 - Particulars to be provided with applications for exemption orders for rail vehicles.

Full name of the applicant

Strathclyde Partnership for Transport (SPT)

The address of the applicant

In the case of a company, this must be the address of its registered or principal office.

131 St Vincent Street
Glasgow
G2 5JF

Description of the rail vehicle

This description of the rail vehicle includes the:

• class number
• unit number
• vehicle number
• name of the manufacturer
• place of manufacture
• date the vehicle first brought into use, (unless not yet brought into use)

4-car Electric Multiple Unit (EMU) for SPT Subway.

Seventeen new trains have been ordered from Stadler AG (via a joint venture contract with Hitachi Rail STS), being manufactured at one of Stadler’s sites in Switzerland.

The subway is physically separate from the United Kingdom (UK) mainline railway and takes the form of a continuous 10.5 km loop with 15 stations, operating entirely underground with a link to the surface to enable empty trains to access the maintenance depot at Broomloan. The subway is not an interoperable railway and therefore the fleet is not listed on the UK’s National Vehicle Register (NVR), so it has no class number. The Stadler AG electric multiple units ordered for Glasgow Subway in 2017 and numbered 301 to 317, with vehicles number 301A, 301B, 301C, 301D to 317A, 317B, 317C and 317D. A full list of individual vehicle numbers forming each unit is shown in Appendix B.

Detailed below is an indicative timeframe around new train delivery, introduction to service and legacy train disposal which will be completed by 30 June 2024.

Description of the services

A general description of the services which the rail vehicle is likely to be used to provide and the routes on which it is likely to be operated.

SPT Subway is the third oldest underground rail system in the world (behind London and Budapest), first opening in 1896. The network is a continuous 10.5 km loop with 2 tracks, each one in its own physically separate tunnel, known as the outer and inner circle, running clockwise and anticlockwise respectively.

The current fleet of trains, built by Metro-Cammell, comprises 33 cars built in 1977 to 1979 for the Glasgow Subway modernisation in 1980, with eight cars added in 1992. The Stadler fleet was ordered as part of the current further modernisation programme to replace the life-expired Metro-Cammell fleet.

The subway has a unique track gauge of 4 feet (1219 mm) and small diameter running tunnels (nominally 3.35 metres). This places severe restrictions on the width and height of the trains, which have a substantially smaller cross-section than the trains operating on London underground’s deep level tube lines. Trains effectively have to be ‘made to measure’ for the subway – there is no ‘standard’ design which is capable of being modified to fit the infrastructure.

In 2011, SPT initiated a major subway modernisation programme covering five main strands:

• smart ticketing (completed in 2013)
• station refurbishment (in progress)
• infrastructure asset renewal (in progress)
• signalling system replacement (in progress)
• new rolling stock (in progress) and
• installation of platform screen doors at all stations

On completion of the full modernisation programme, the system will migrate to Unattended Train Operation (UTO), with all trains controlled and monitored from a new Operational Control Centre (OCC) to be built at SPT’s existing Broomloan depot.

The first new trains are scheduled to enter passenger service January 2023 to March 2023 when there will be a period of mixed fleet operation, with the new trains running in service with our legacy fleet. As each new train enters service, it will replace one of the legacy fleet which will then be withdrawn.

Since the body-side doors are in different positions on the existing and new units, the platform screen door installation programme cannot start until all existing units have been withdrawn from service. Platform Screen Door (PSD) installation will commence immediately afterwards and the programme is scheduled for completion in 2025. The new train fleet will then be converted to operate in UTO Mode (which will involve conversion of the temporary driver’s cab to a passenger saloon).

The provisions of RVAR from which exemption is sought

SPT are applying for 1 exemption detailed below.

Part 1, General Requirements, paragraph 13(3):

Each priority seat, and the space available to its user, must comply with the specifications shown in Diagram C1 and in either Diagrams C2, C3 or C4 in Schedule 2.

Section 6 – C1 and C2 are the exemptions SPT are applying for.

The technical, economic and operational reasons for the application

Part 1, General Requirements, paragraph 13(3)

Due to the limitations on vehicle interior height and width posed by the tunnel profile, the priority seats do not meet the required dimension for clear headroom on the curved profile of the ceiling above them. The headroom is as large as can be achieved, given the need to meet essential safety requirements for the vehicle structure and gauging. Images and actual measurements of the vehicle against RVAR measurements are attached as Appendix A; please refer to attachment ‘SPT new vehicle seating position measurements’.

All of the fixed passenger seats on the train are mounted longitudinally along both body-sides and so the headroom dimensions are the same for all seats.

Effect of non-compliance

The effect which non-compliance with the provisions referred to in the provisions of RVAR section would have on a disabled person’s ability to use the rail vehicle.

The non-compliance with the minimum headroom dimensions for the priority seats is very small. We have already commenced engagement with Mobility and Access Committee for Scotland (MACS) around our system and services. We have agreed in the next few months to invite MACS to return to view one of the new trains and seek their suggestions on the reduced headroom.

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

No changes to the vehicle design are proposed to increase the available headroom above the priority seats. It is unfortunately impossible to increase the height of the vehicle without re-boring the running tunnels along the whole length of the network. The cost of such a programme and the disruption it would cause to passengers would be grossly disproportionate to the accessibility benefits.

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

An exemption order against RVAR Part 1 Paragraph 13(3) is sought for the life of the new fleet.

Prior consultation

Where prior consultation with the operator of the rail vehicle is required by regulation 3(2) of the Rail Vehicle Accessibility (Applications for Exemption Orders) Regulations 2010, please set out the response of the operator to the consultation.

No consultation required as SPT is the vehicle operator.

Appendix B: list of unit and vehicle numbers

Unit Number	Coach A	Coach B	Coach C	Coach D
301	301A	301B	301C	301D
302	302A	302B	302C	302D
303	303A	303B	303C	303D
304	304A	304B	304C	304D
305	305A	305B	305C	305D
306	306A	306B	306C	306D
307	307A	307B	307C	307D
308	308A	308B	308C	308D
309	309A	309B	309C	309D
310	310A	310B	310C	310D
311	311A	311B	311C	311D
312	312A	312B	312C	312D
313	313A	313B	313C	313D
314	314A	314B	314C	314D
315	315A	315B	315C	315D
316	316A	316B	316C	316D
317	317A	317B	317C	317D

Respond to this consultation

If you have any comments or feedback you would like to provide regarding this consultation then please find contact details under our ‘ways to respond’ section.