Mr Grayling is wrong about the Brexit dividend to station platforms

It is seldom a pleasure to hear the droning, humourless and untrustworthy voice of the Transport Minister Chris Grayling, and never less so than when he interrupts preparations for Sunday lunch.

Unfortunately I wasn’t able to get to the off button quite in time, so I caught Mr Grayling being interviewed by Mark Mardell on The World This Weekend. Yesterday was of course the day when Theresa May announced her Great Repeal Bill, and this was the subject of Mr Grayling’s interview. Before I pulled the plug on him I heard this exchange:

Q: I imagine there are lots of laws in your area of transport both in aviation & road transport that are affected by EU legislation. Any you want to get rid of?

A: Well let’s get back to some practical examples, there are EU laws around the running of railways about the height of platforms, for example. Our rail system, apart from HS1, is not in any way linked to the continental rail network, so there is actually no reason for us to have European platform heights, so that’s one area of regulation that could certainly change.

For some reason this immediately brought to mind lines from the Wilfred Owen poem “Futility,” written about a very different subject matter:

Was it for this the clay grew tall?

O what made fatuous sunbeams toil

To break earth’s sleep at all?”

All the sound and fury of the referendum battle, all the political blood that has been spilt, all the poisonous, dishonest and occasionally racist rhetoric: what has it achieved?

It has given us back the freedom to set our own platform heights.

A miserable crow on a low German railway platform
A miserable crow on a low German railway platform

I daresay Mr Grayling, like most of us, has often sat on British stations, perhaps eating unnaturally straight bananas, while cursing the Euro-madness that mandates the height of the platform. He probably mused that generations of young men did not die in two world wars so that faceless pen-pushers in Brussels, some of them German, could tell us that our platforms were the wrong height. How absurd that we are not allowed to have platforms at the good old English height of 915mm, or rather 36.0236 inches.

At last, Brexit has given us the chance to build our platforms as high or as low as we like. It is a heady opportunity that we should seize with both hands. And what immense good fortune that we have in Mr Grayling a Transport Secretary with the breadth of imagination to point it out, and the force of personality to transform every railway station in the land.

Yet something still niggled. Some Brexiteers, even Mr Grayling himself, have occasionally been accused of a certain tendency towards economy with the actualité.

I decided to look into the matter. What difference will Brexit make to British platform heights?

Is Mr Grayling right that leaving the EU will allow us to restore our platforms to their former height and glory?

Or has he pretty much invented a non-existent problem so that he can pretend that Brexit provides a solution to it?

First of all, as he conceded by implication, the Eurostar service that uses the Channel Tunnel might as well keep its existing platform heights. Stirring, patriotic and intensely symbolic though it might be to bring in the builders to reconstruct our Eurostar platforms to a distinctively British height, in every other way it would be pointless, inconvenient and expensive. The same presumably goes for the HS2 platforms, should any ever be built.

Mr Grayling’s proposal is therefore aimed at ordinary domestic railway platforms; the sort at which hard-working families wait, often in bracing British rain and cold.

I freely admit that I am no expert on the conflict of laws relating to the height of railway platforms. I will happily defer to anyone with the time and energy to prove me wrong. But as far as I have been able to determine:

  1. Existing British domestic platforms are currently allowed to be different heights from those in continental Europe;
  2. New British domestic platforms can still be built at the traditional British platform height.
  3. The regulations which are aimed at the modest standardisation of platform heights in Europe do not require Britain to alter the height of our platforms.

So Mr Grayling is wrong about railway platform height in every possible way. If you want the detail I’ve done my best below.

Existing Platforms

This is a very recondite subject, and I confess to taking my information about existing European platform height from Wikipedia.

The height of platforms varies wildly both across the EU, and within different countries within the EU. Broadly speaking British and Irish platforms have been built at 915 mm high. German platforms can be any height from 380 mm to 960 mm. French, Polish, Danish and Czech platforms are usually 550 mm, while zany little Belgium has a huge variety of platform heights, with some as low as, or even lower than 280 mm. The point is that at the moment more or less anything goes on ordinary non-high-speed lines.

European law on standardisation

That’s all very well, you might say. But what about the future? Doesn’t Europe have a plan to crush our sovereign right to build platforms at 915 mm?

At first sight Mr Grayling seems to have a point. A mind-numbingly dull Euro Regulation [(EU) No 1299/2014] does indeed set out to standardise railway infrastructure across Europe by issuing “technical standards for interoperability” (TSI) which must be complied with by national governments. They apply to “all new, upgraded or renewed ‘infrastructure’ of the rail system in the European Union ….” In other words, member states are required gradually to standardise their infrastructure.

If you’re still with me, go now to paragraph 4.2.9.2 of the regulation:

(1) The nominal platform height shall be 550 mm or 760 mm above the running surface ….”

There then follows a list of various exceptions for non-standard gauge railways, none of which need concern us now, except perhaps to note that Ireland, which has a wider gauge than Britain, is expressly allowed to keep its 915 mm platform height.

So, on the face of it Mr Grayling is right. The EU has condemned our perfectly good platforms to be gradually lowered to make them more European. And to add insult to injury it’s allowing the Irish to keep theirs as they are.

But he’s not right. If we look a little more closely at the detail of the regulation we come to paragraph 7.7.17.: “Particular features on the UK network for Great Britain.” In effect this gives Britain an “opt-out” (though it doesn’t use that phrase) from the regulation about platform heights (as well as an opt-out allowing us to continue using MPH instead of Km/H), and at paragraph 7.7.17.6 it says this:

Instead of point 4.2.9.2, for platform height, national technical rules as set out in Appendix Q shall be allowed.”

Head now to Appendix Q, and we come to the “technical rules for UK-GB specific cases.” A table is set out which includes a section called “Interface between Station Platforms, Track and Trains,” and refers us to yet another document, “GI/RT7016.” This is produced by the Rail Safety and Standards Board, a British organisation that amongst other things produces technical guidance for railway operators. The part of the document relating to platform height is a model of clarity.

For new platforms and alterations (as defined) to existing platforms, the height at 3.1.1 the edge of the platform shall be 915 mm (within a tolerance of +0 mm, 25 mm).”

In other words, a British organisation has been given the freedom by the EU to set its own standards for railway platform height, and it has done so by fixing platform heights at the traditional British height.

So almost everything Mr Grayling said about platforms seems to be wrong. Britain doesn’t have “European platform heights,” at the moment; in fact the EU itself doesn’t have standard European platform heights (it has lots of different ones), and although there are moves to introduce a measure of standardisation into European platform heights, they will not require Britain to change the heights of our existing or new platforms in any way. The whole thing appears to be a complete nonsense.

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Author: Matthew

I have been a barrister for over 25 years, specialising in crime. You may also have come across some of my articles I have written on legal issues for The Times, Standpoint, Daily Telegraph or Criminal Law & Justice Weekly

48 thoughts on “Mr Grayling is wrong about the Brexit dividend to station platforms”

  1. You made me laugh hard

    No Italian or Greek example? We the southerner leeches protest! Surely there must be fun ones in the land of fascist railways?

    1. Nope,
      “Surely there must be fun ones in the land of fascist railways?”

      The fun railway feature of Italy is that boards with the station name are often at right angles to the platform, so the driver can see them, but not the passengers. Fine for Milano Centrale, not for suburban stations. So you have to hop out of the train to see the name. The platforms are “very” low, and you have to be quick, or you’re left at a dusty no horse town in the middle of the Po valley with two hours till the next train.

      1. For the sake of Truth, in every railway stations I’ve been in my country (Italy) I’ve never seen boards at right angle to the platform. Always parallel

  2. And examples like this can be found all over EU legislation. We had endless opt-outs. We had a good deal. And we blew it. So, so sad.

  3. And what about the railtrack (!) – when Europeans sell trains to us the rolling stock needs to be tested for the UK network. Since the Germans have no rails in their own country of such distinguished character and ‘UK quality’ the engineers have to attack a pristine section of German track with sledge hammers and mallets in order to recreate that distinguished ‘UK feel’.

  4. You missed out mentioning Holland, where many of the platforms are at the British height of 915mm because much of their railway system was built by British engineers.

    When Switzerland started receiving direct high-speed trains from Germany (ICE1), certain stations had to have changes made to their platforms, not to meet some EU Regulation but simply so that passengers could get on and off the trains. The result was that the railway authorities had to construct a continuous steel step the length of the platform so that passengers could get on and off the train safely.

    I also heard Chris Grayling in that interview. Words cannot express my contempt for the man.

    1. Yes I remember the Swiss ICE steps. The Platform at Interlaken west was very low and even with the steel step it was an exercise in mountaineering to board an ICE (though it did make it much easier for Swiss trains) – Eventually they raised the platform properly.

  5. So. Will this mean that the average trainspotter (one presumes a variety of UK citizen which has a rather high share of Leave voters) will now reconsider their decision? Will we see furious protests by anoraks descending on Whitehall protesting either i) the obvious cluelessness of Mr. Grayling; or ii) the nefarious interference of the EU in this matter?

    At least the author is no expert on the matter, so he must be right.

  6. What! Are you telling me that a respectable yet inept jingoist of the Brexit variety is just making stuff up to justify his deep and irrational hatred of the EU? Shocked I am.

  7. So Grayling is happy to commit economic suicide, just as long as railway station platforms are the “correct” height. I really don’t know whether to laugh or cry.

    1. Yes – which is why the EU is standardising. New low floor regional trains in Europe offer step free boarding (for example the new Leipzig S-Bahn trains are not only level with the platform, but also extend a step to fill in the gap between the train and platform.) and the Swiss are currently building the first low floor high speed train.

  8. Grayling’s an idiot, but we knew that. However, you do prompt in me the question ‘What the hell is the EU doing trying to decide anything about any rail platforms anywhere?’ If it had stuck to important stuff and been less keen to intrude into every conceivable area of life perhaps the vote might have been different.

    1. If you ever leave the shores of this sceptred isle, you may notice that other European countries are gravely deficient in shoreline, and rather one country simply abuts another, the poor things. In light of this, some clever foreign sorts conceived of the idea of running railway lines from one country to another; so one can, for instance, travel from Paris to Brussels merely by taking a direct train, without needing to change at the border.

      Given this, you can perhaps imagine the difficulties caused by platforms being of different heights where you board the train, from where you alight; the train cannot easily be at the right height for both stations. You might board the train easily, but face an unexpected severe drop when disembarking, or the other way around. Most inconvenient.

      It is therefore in everyone’s interest, in continental europe at least, to agree what height to build platforms to, so that passengers can board in one country and alight smoothly in another. Due to our splendid isolation however, it is less important for us to do so.

      The sensible solution, therefore, would be for continental countries to agree a common platform height, without seeking to impose upon the UK or Ireland, whose railways are mostly separate. And lo and behold, this is exactly what was agreed.

      1. ‘Tom’ – thanks. With respect, if I may say so I fear that the style of your reply is rather typical of the condescending attitude of many of your fellow remainers, and indeed it may have been a factor in the loss of the vote.
        How ironic, if that were true.
        As it happened, I lived in Paris from 1994 to 2013, and funnily enough I noticed the contiguous nature of the majority of the continent – travelling regularly, as I did, for business across northern Europe, often by train, it was hard not to.
        I believe – though I cannot be sure – that most of the indigenous peoples of the countries through which I travelled also noticed this not-unique feature of their national borders.
        (Of course, I cannot entirely discount the possibility – which you seem to be assuming? – that they are all simpletons, and could not notice this without the assistance of the bureaucratic machine in Brussels.)
        Platform height was never an issue during my travels to various European cities (including – ha! – Brussels), but insofar as it was I think it was something which the individual nations might easily have dealt with themselves, on a case by case basis, if they felt it important enough.
        I repeat: if the EU stuck to the important stuff in life we might not have voted to leave.
        But it does seem that it can’t help itself.

        1. “it was something which the individual nations might easily have dealt with themselves”

          They did – by joining together to come up with a single standard. Nothing else makes sense. If Germany negotiated a standard with France and another with Poland then they would need different rail stock depending on which route was going to be used – playing havoc with domestic trains that happen to stop at some of the same stations. Companies making rail stock would have been thrilled as well, presumably pushing up costs as they make 32 different models.

          These situations of needing a standard exist in all sort of areas – transport, telecommunications, post etc – and even before the EU bodies were formed to set such standards. Look at CEPT or the EBU for example. Sometimes the choice of standard is mostly arbitrary (like railway platform heights I would guess) but it still needs someone to set them. Setting these standards is (was?) one of the best things about the EU.

      2. Also, it’s not only passengers, but train makers – so you don’t need to make a train that has floor at 30, 50, 90 and whatever else you can find centimeters, but can standardise for the EU market.

  9. Matthew, may I suggest a small addendum. Heathrow Express was built with 1100mm platform height (above rail level):

    “The platform edge clearances are subject to derogation from the NR standard to minimise the gap between platform and train step-boards with a height of 1100mm”. [Heathrow (2015), p.15, http://www.heathrow.com/file_source/Company/Static/PDF/Companynewsandinformation/rail-network-statement-june15.pdf%5D

    This 1100mm height has continued to be deployed for other new infrastructure projects. In May 2013 Crossrail and Thameslink raised their intention with the RSSB:

    “proposals from Crossrail and Thameslink to use 1100mm platforms” [RSSB (2014), p.1 §2.1
    http://www.rssb.co.uk/Library/about-rssb/2014-proposals-development-of-gb-strategy-managing-platform-train-interface.pdf%5D

    Which lead to the work on the second edition of the Passenger Train Interface stategy:

    “Various train operators in GB have required platforms with heights which differ from the 915mm RGS requirement for new build. … Heathrow Express, London Overground (TfL section only), … Crossrail central section. … some Thameslink core stations” [RSSB (2015), p.24, http://www.rssb.co.uk/Library/improving-industry-performance/2015-01-platform-train-interface-strategy.pdf%5D

    In summary: The most frequent new-build platform height on the GB rail network already differs from the mandated Euro TSI 550mm/760mm and GB 915mm nominal heights.

  10. I am delighted that the fact that EU regulations do not actually mandate european platform dimensions for the UK is now clearly understood despite Mr Graylings words!
    I have had occasion to investigate UK platform geometry and interestingly the best I can get to in terms of the provenance of the dimensions from rail position is
    Vertical 915mm above rail level is a metric yard – presumably navvies were sent out with a Yardstick to build platforms and did not need to be able to read!
    Lateral 730mm from rail has no immediately obvious provenance and I would welcome views – best I have heard is that it is a dimension that puts the platform edge 2″ clear of the cylinders of a GWR “King” class steam locomotive, a type known to have been demanding in terms of route clearances.

  11. Who cares about the height of a platform? When getting on or off a train my only concern is the height difference between the platform and the carriage exit. Steps are a pest and dangerous. (I read somewhere that after car accidents, steps are the main cause of accidental death.) EU standards to minimise the ‘jump distance’ would a benefit for all of us.

  12. Grayling is so totally ignorant of his brief that he seems to think that Britain’s only direct connection with continental railways is through the HS1 line. He doesn’t seem to know that freight wagons and the Duke of Windor’s favourite sleeping car train, The Night Ferry, used to travel directly across the Channel long before the tunnel was opened. Today, long freight trains hauling bottled water from the South of France and car parts from Poland cross from the continent every day and night. There is even a direct freight train from Scotland to Wroclaw in the opposite direction, usually loaded with whisky.
    In a country about to commit industrial hara kiri, he looks just the man for the job.
    I don’t suppose, judging by his allegations about EU standardisation, that he knows that continental trains, particularly the Thalys high speed trains between Paris, Amsterdam and Cologne, still have to cross over from running on the left in France and Belgium, where British and Irish engineers built the first railways, to running on the right in Germany and the Netherlands, where they built their own railways. This quirky procedure takes place in various interesting places, especially on a flyover deep in the forests between Liege and Aachen.

  13. What Grayling was probably referring to was HS2, which wants to have 1100 mm high platforms in order to have level access from platforms to trains and high floor heights to allow for the large wheels needed for high speed running (to dissipate heat) without internal steps. As it’s a new piece of railway, it is not eligible for a dispensation from the TSI. But the level access would only apply at the handful of new platforms HS2 is intending to build. Most calls would be at existing stations where there’d be a vertical step of 185 mm up/down from/to the platforms (assuming they’re currently at or near the 915 mm British norm), requiring the continuing use of ramps (or platform humps) by passengers with impaired mobility.

    Disability organisations and other train/station operators regard this notion as deeply retrograde, but Brexit may allow HS2 to get away with it. HS2 could use trains with floors at 915 mm height, but would have to allow the wheels to penetrate the floors (as on tube trains) which would reduce the floorspace and thus carrying capacity.

  14. Sorry – A correction to my previous comment (which I should have checked before sending). The train floor height HS2 is seeking is 1200 mm, not 1100, so the vertical difference from existing British platforms at the standard height would be 285 mm – i.e. about 11 inches.

  15. This is such a stupid, nasty and petty article, I will no longer follow your blog.
    You are like so many others, full of rancour because you lost.
    “All the sound and fury of the referendum battle, all the political blood that has been spilt, all the poisonous, dishonest and occasionally racist rhetoric: what has it achieved? ”
    If you can’t understand what it has achieved, you are too stupid to be worth arguing with.
    And just for good measure, all the “racist rhetoric” I heard , months of it, was anti-English racism. Insisting the English are far too stupid to govern themselves and that independence somehow makes people “little”.
    Better blogs than this out there!

  16. While there is an exception for platform heights the extension of the interoperability rules to the whole of the British network in 2015 requires us to design new routes to take EU size trains. These are wider and longer than UK trains and therefore new platforms set back further from the tracks (and stations) are required. DfT have always claimed it is a legal requirement to design HS2 to the EU rules.

    The problem is complicated because in 2014 HS2 realised that passengers would not be able to get on to high speed trains in the time allowed unless platforms are the same height as the train. They want the EU to agree to a new platform height of 1200mm or so. It looks like EU won’t agree to this. Whether Grayling has been told the full story I don’t know but he must know there is an issue. It’s about time he found out what is going on and confessed that we have wasted £2 billion on a scheme that few people want.

    I see John Cartledge has said something similar. Will DfT ignore the EU rules or will someone pull the plug on this ludicrous project?

  17. Not sure that trainspotters – who may prefer to be called railway enthusiasts or “gricers” – are particularly likely to be Brexiters. There are enthusiast magazines dedicated to continental railways and companies which organize continental rail tours. Portillo is apparently a Brexiter, but he can afford to be, since he flashed his two passports on one of his continental railway journeys. When Michael Denzil Portillo’s British passport no longer guarantees freedom of movement, the Spanish passport of Miguel Portillo Blyth will do fine.

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