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It's always been feast and famine in the rolling stock business – but when Disability Legislation bites the market could go mad
One of the stock cop-outs for the failures of privatisation is ‘decades of underinvestment'. As big lies go it has a lot going for it.
For a start all the political parties sign up to it. If ‘we are all guilty' then today's problems are no one's fault and we can all ‘move on'. Mass ‘mea culpa's' absolve the Conservatives for wrecking a fully functioning cost effective railway and Labour for watching the wreck break up.
Silly me, of course it can't have been a fully functioning railway, because of decades of underinvestment. The reason why the railway soaks up five times as much taxpayers' money, is because everything was run down during those decades of bread and scrape and we are now playing catch-up.
Take the Rolling Stock companies (ROSCO). Only thanks to private capital were we able to spend over £5 billion on all those shiny new trains. British Rail would not have done it, could not have done it, according to the privatisation proselytisers
But, rather like Arnold Schwarzenegger in the film ‘Total recall', I keep getting these flashbacks in which the car park watchers are observing tenders being delivered for Sprinters and Networkers and IC225s. And when I ran a comparison back in 2004, I found that in the 10 years before 1994 BR ordered, roundly, 4000 vehicles: in the following 10 years the ROSCOs had ordered 4,400 – only 10% more than in a decade of underinvestment.
So the proximate cause of the emerging Ballybunion Vortex I am about to describe is British Rail, which failed to conform to the political stereotype and ordered trains when it should have been running the traction and rolling stock fleet into the ground. Quite a lot of trains, in fact.
Table 1 shows the vehicles in what are known as the MOLA fleet – the traction and rolling stock inherited by the Rolling Stock Companies in 1996 and covered by the Master Operating Lease Agreement (MOLA). They represent roughly half of the total passenger fleet and were all built between 1975 and 1994. But the dates which matter are 1985, 1998 and 2020.
Why 1985? Well, when the ROSCOs were sold, their assets were valued on the basis of a nominal 35 year book life. So anything built before 1985 will be written down by 2020.
Why 1998? Because all vehicles built after from November 1998 have to comply with the Rail Vehicle Accessibility Regulations (RVAR). And the RVAR brings us to 2020.
Under the Disability Discrimination Act (DDA) 2005 all rail vehicles, including those built before the RVAR came into force, will have to be fully RVAR compliant from 1 January 2020 . Readers will recall that this column recorded the wrangling between the ROSCOs and DfT over this drop dead date The disability Taliban wanted 2017 and the ROSCOs suggested 2030, by which time n the last Networkers would have seen out their book life.
For a time it looked as though the compromise would be 2025, but in the end the DfT, came over all cuddly and wobbly and went for 2020. And now, thanks to BR's unwonted profligacy, they face a monster problem of their own making.
To DfT Rail's credit, they, or rather my old chum Clive Burrows now the Rail Group's Director Technical & Professional, have started peering into the abyss.
Fig 1 is a chart from a presentation Clive made last October. It shows what happens if total RVAR compliance by 31 December 2019 is mandatory.
Pre RVAR vehicle totals |
||||
|
EMU |
DMU |
LHC |
Total |
L&SE |
2979 |
343 |
|
3322 |
Regional |
519 |
1203 |
|
1722 |
InterCity |
|
|
953 |
953 |
Grand totals |
3498 |
1546 |
953 |
5997 |
DfT replacement estimates |
3650 |
1565 |
1190 |
6405 |
Table 1 shows my estimate of the number vehicles affected by DDA 2005. As a cross check I have scaled the number of replacement vehicles in Fig 1 and these totals are shown at the bottom of the table.
Don't be two concerned about small differences. In the case of the InterCity fleet, for example, I have not included locomotives or power cars.
So, if RVAR compliance is interpreted to the millimetre, in round numbers 6000 vehicles will have to be replaced by December 31 2019 .
Tables 2,3 and 4 show the vehicles affected in more detail. Note that I have highlighted the small number pre-1985 vehicle. All the rest have nominal withdrawal dates the other side of 2020. Note, ‘nominal' and remember that the earliest IC125s will be at least 40 years old on retirement.
Class |
Type |
Trains |
Total vehicles |
Build years |
IC125 |
Mk 3 |
69 |
563 |
1975-1982 |
Loco hauled |
Mk 3 |
14 |
120 |
1984-85 |
IC225 |
Mk 4 |
30 |
270 |
1987-1990 |
Total |
|
113 |
953 |
|
Class |
Type |
Units |
Total vehicles |
Build years |
Class 313 |
EMU |
64 |
192 |
1975-77 |
Class 315 |
EMU |
20 |
80 |
1980 |
Class 317 |
EMU |
72 |
288 |
1981-1987 |
Class 319 |
EMU |
93 |
372 |
1987-1990 |
Class 321 |
EMU |
113 |
452 |
1988-90 |
Class 365 |
EMU |
40 |
160 |
1994-96 |
Class 442 |
EMU |
24 |
120 |
1997 |
Class 455 |
EMU |
137 |
548 |
1977-1985 |
Class 456 |
EMU |
24 |
48 |
1990-91 |
Class 465 |
EMU |
147 |
588 |
1991-94 |
Class 466 |
EMU |
43 |
86 |
1993 |
Class 508 |
EMU |
15 |
45 |
1979 |
Total EMU |
|
792 |
2979 |
|
Class 150 |
DMU |
8 |
16 |
1987 |
Class 153 |
DMU |
5 |
5 |
1988 |
Class 156 |
DMU |
9 |
18 |
1987-89 |
Class 159 |
DMU |
22 |
66 |
1992 |
Class 165 |
DMU |
74 |
175 |
1991-93 |
Class 166 |
DMU |
21 |
63 |
1992 |
Total DMU |
139 |
343 |
|
|
Combined totals |
931 |
3322 |
|
|
Class |
Type |
Units |
Total vehicles |
Build years |
Class 142 |
Pacer DMU |
94 |
188 |
1985 |
Class 143 |
Pacer DMU |
23 |
46 |
1985 |
Class 144 |
DMU |
23 |
56 |
1986-88 |
Class 150 |
DMU |
119 |
258 |
1984-87 |
Class 153 |
DMU |
65 |
65 |
1987-88 |
Class 155 |
DMU |
7 |
14 |
1987 |
Class 156 |
DMU |
105 |
210 |
1987 |
Class 158 |
DMU |
170 |
366 |
1989-92 |
Total DMU |
|
606 |
1203 |
|
Class 314 |
EMU |
16 |
48 |
1878-80 |
Class 318 |
EMU |
21 |
63 |
1986 |
Class 320 |
EMU |
22 |
66 |
1990 |
Class 321 |
EMU |
4 |
16 |
1990 |
Class 322 |
EMU |
5 |
20 |
1991 |
Class 323 |
EMU |
43 |
129 |
1993 |
Class 507 |
EMU |
32 |
96 |
1978 |
Class 508 |
EMU |
27 |
81 |
1979 |
Total EMU |
|
170 |
519 |
|
Combined Totals |
|
776 |
1722 |
|
Were the 2020 drop dead date for full RVAR compliance to be strictly applied, and if deliveries of replacement vehicles started in January 2008, we would have to build 500 vehicles a year to meet the deadline. So far, the only fleets scheduled for replacement are the East Coast and Great Western IC125 and IC225 high speed trains under the Intercity Express Programme (IEP).
But the heart of the problem lies in the legacies of Regional Railways and Network Southeast. Refurbished, many of these 5,000 multiple unit vehicles could run on to 2030 or even beyond. But this would depend on the interpretation of the RVAR being eased to allow cost effective modifications as part of the refurbishment programme.
Even then a time constraint remains. Fleets are already tight and refurbishment capacity finite, imposing limits on the number of trains which could be withdrawn at any one time.
That nominal 35 year book life also affects timing. The Class 321 fleet was built in 1998-90. This means that it will be written down in 2025. The later you leave modification for RVAR compliance the less time there is to recover the cost through rentals and rentals will have to go up.
But suppose that early agreement could be reached on the ‘soft RVAR' specification proposed later and compliance modifications could be combined with refurbishment programmes over the next seven years, say. Then, the cost of ‘soft' compliance be reduced. And with a minimum of 10 years service life ahead the increase in rentals would be small.
Precedents exist. With some fleets Rolling Stock Companies have maintained existing rentals after refurbishment. The longer commercial life paid for the work.
With IC125 refurbishment, we are already seeing up to £150,000 being spent on a 30 year-old Mk 3 coach, to give another 10 years of front line service. This does not include major work on RVAR compliance, although accessible toilets are being fitted.
For the work-horse multiple units which form the bulk of the MOLA fleet, refurbishment costs are quite modest. But this makes RVAR compliance modifications proportionally more expensive as an add-on. The key cost area in meeting the RVAR are accessible toilets, door widths, heights of grab handles and door buttons and Passenger Information Systems.
To take a practical example, door operating buttons have to be not less than 700mm and not more than 1200mm above the vehicle floor. The button in the Class 323 (book life to 2028) is 1250mm above the floor.
Now the range specified in the RVAR, is, according to the guidance on the Regulations intended to ‘encompass a reach that is comfortable not only for wheelchair users, but also people of restricted growth and people with arthritis who may have difficulty in raising their arms'. Is another couple of inches going to detract significantly from personal mobility? I think not.
And dropping the buttons by 50mm on the Class 323 would be expensive because of the way the external button works. When you push the button on the door, it moves a short rod which pushes a button on the bodyside. Moving these bits down would mean modifying door panels and body.
Grab handles also come within the 700-1200mm rule. The problem here is the attachments points which have to be bolted to the body structure. You might think the answer would be to fit longer handles on the same mounting points, but handles have to be unobstructed between 700mm and 1200mm.
Then there are internal doors which have to be 850mm wide, although end gangway doors are allowed to be only 750mm wide because of the need to maintain structural strength. Since the reference wheel chair is 700mm wide, is 850mm really that essential?
Finally, toilets. Universal access toilets are not new. We have them on my local Class 365 Networkers and jolly useful they are too, even though they are not fully RVAR compliant.
Apart from minor changes to grab handles and so on, the real obstacle when updating pre-1998 accessible toilets is the requirement to be able to transfer between chair and toilet from both the front and the side of the wheelchair. This means that the toilet has to be long and wide: pre-RVAR universal access toilets are smaller.
So, the first step towards reducing the scale of the approaching MOLA fleet crisis must be to ‘soften the RVAR' with the aim of providing adequate disability provision in pre-1998 vehicles at reasonable cost. And changes to the legislation must be put in train now.
For starters, modifications would be simpler, and the volume of work reduced, if a plus or minus 10% tolerance applied to dimensions in the RVAR for pre-1998 vehicles. This would also mean that more could be spent on, say, retrofitting accessible toilets.
Here, cost would be avoided if transfer were to be either from front or side but not both. Presumably both modes are not equally popular so why not adopt the majority preference. While I am trying to be sweetly reasonable, we should not forget the option to take out toilets altogether on the grounds of increased capacity.
Of course, having got the 2020 deadline into law, the Disability Taliban are going to get all self righteous over the thoughtless attack on their community expressed in this article. We can rely on them to fight to the last irrelevant millimetre.
But the plain truth is we have neither the time nor money to replace everything pre 1998 in the next 12 years. Remember that there are nominally only 1000 new vehicles in the High Level Output Specification – which covers the five years 2009-2014.
In the five years after that funding will be dominated, in theory at least, by the IEP. This is proposed as a 30-35 year total train service provision package, but with coming on for £2billion of trains plus depots, plus a positive plethora of multiple risks to be covered the monthly payments won't be cheap – even by the exorbitant rates charged by the ROSCOs for their MOLA fleets. (that's enough heavy irony Ed)
So some time in the next five years tolerance and modification, rather than replacement, will become the only way forward for RVAR compliance. Figure 2 shows DfT Rail's view of future builds, assuming that selected fleets are modified to be RVAR compliant. While builds in the 2030s may be of intellectual interest, what counts is the period to 2020.
Fig 2) Some stock modified to comply
By correlating the build quantities in the two DfT Rail figures. We get an indication of the number of vehicles to be modified . The result is Table 5. Table 6 provides further simplification.
|
Electric Inter-urban modified |
Diesel Outer modified |
Intercity electric |
Electric Inter-urban |
Electric Suburban |
Intercity diesel |
Diesel Outer/inter regional |
Diesel Suburban |
Total |
Some stock modified to comply |
1880 |
910 |
280 |
130 |
1490 |
910 |
0 |
675 |
3485 |
All pre-1998 stock withdrawn |
|
|
280 |
2160 |
1490 |
910 |
910 |
655 |
6405 |
Modified stock highlighted in grey
RVAR modification |
Vehicles |
EMU |
1680 |
DMU |
910 |
Total vehicles modified |
2590 |
Replacement build |
|
Intercity |
1190 |
EMU |
1620 |
DMU |
675 |
Total |
3485 |
As a double check I have identified individual classes which could run on past 2020 if made RVAR compliant (Table 6). Bearing in mind that much of this is back of the envelope stuff, there seems to be a reasonable correlation between DfT Rail's analysis, which implies 2590 vehicles modified for RVAR compliance and the 3396 vehicles in my fleet-based analysis. Scrap the Class 150s and the Class 317s and there's only 10% difference
LSE long life fleets |
||
EMU -No of vehicles |
||
Class 317 |
288 |
|
Class 319 |
372 |
|
Class 321 |
452 |
|
Class 365 |
160 |
|
Class 465 |
588 |
|
Class 466 |
86 |
|
Total |
1272 |
|
DMU -No of vehicles |
||
Class 156 |
18 |
|
Class 159 |
66 |
|
Class 165 |
175 |
|
Class 166 |
63 |
|
Total |
322 |
|
Regional long life fleets |
||
DMU -No of vehicles |
||
Class 150 |
258 |
|
Class 156 |
210 |
|
Class 158 |
366 |
|
Total |
834 |
|
EMU -No of vehicles |
||
Class 318 |
63 |
|
Class 320 |
66 |
|
Class 321 |
16 |
|
Class 322 |
20 |
|
Class 323 |
129 |
|
|
294 |
|
This analysis reveals the scale of the 2020 challenge and highlights the need for an early decision on combined refurbishment/soft RVAR compliance work programmes. For once, cost is not a major issue.
Depending on the scale of the work needed, I estimate that soft compliance would cost £50000-70,000 per vehicle. Round it up and the worst case cost RVAR modification on-cost is under £300million over, say, seven years.
It is providing the resources to plan, design, procure equipment and do the work, while minimising the impact on train availability, which is the real issue. This is why combining RVAR modification with refurbishment is such a powerful multiplier. And don't forget that refurbishment should include reliability modifications such as those I wrote about on the Class 319s
But even with life extension, DfT Rail's figures show just under 2300 vehicles needed to replace life expired EMUs and DMUs between now and 2020. Note that the much vaunted 1000 vehicles in the HLOS are additional.
Note, too, that Fig 2 includes a London Growth Build, which I have not shown in the tables. This assumes 1930 additional vehicles between 2008 and 2020 inclusive.
And when decisions aren't taken, promptly, as I expect to be the case, watch for the first Ballybunion vortex to go hypersonic