News Desk
A Lot of Noise
15th August 2009
Modern technology makes it as easy to annoy people as it
does to make their world better. A mobile phone is a
blessing for some but a serious annoyance to others who
have to share the same space. Now train operators are
being accused of annoying passengers with incessant
announcements that make it hard to relax, even in the
so-called quiet coach. South West trains has generated
such a furore on the Portsmouth line that MP David
Willets has taken up their cause and complained to rail
watchdog Passenger Focus, citing 31 announcements given
in a 32 minute journey. Naturally this has attracted the
attention of the newspapers (for this is the silly
season); they have jumped on the opportunity to print a
‘bad news’ rail story and failed to pick up on other
train operators who are at least as bad.
To be fair train operators have to wrestle with
impossible demands to reconcile the conflicting
requirements placed upon them. One might think that
common sense might apply to the making of audible
announcements, but unfortunately the government has
decided it can do a better job and has promulgated the
Rail Vehicle Accessibility Regulations which are often
quoted as the reason for certain kinds of apparent
madness. South West trains went one better and blamed
the European Union. Their spokesperson in nearby Perth
said “South West Trains admitted other customers have
complained that there are too many announcements”. The
company says “they are in accordance with EU
regulations, which state all trains have to display and
announce information regarding the destination and
upcoming stops”. So that’s alright then. It doesn’t
explain the lengthy tracts read out on East Coast main
line services leaving Kings Cross that sometimes go on
for so long trains are north of Finsbury Park before the
conductor runs out of breath. This is clearly nothing
for which even the EU can be blamed. What other industry
would greet passengers with such negative and lengthy
greetings when enjoying their service?
So what do the regulations actually say? We are talking
about the Rail Vehicle Accessibility Regulations 1998
(SI 1998 No 2456) made in order to apply certain aspects
of the Disability Discrimination Act 1995 to railway
vehicles, and made under Section 46 of that Act. The
regulations apply to all new vehicles introduced on or
after 1st January 1999, and to other vehicles which have
been ‘substantially rebuilt’ after that date (though
this does appear to be DfT interpretation).
Regulation 13 covers passenger information. Subparagraph
1 requires vehicles to be fitted with visual and audible
public address systems. Subparagraph 4 requires both
systems to be used to announce the destination of the
vehicle when the vehicle is stopped. Subparagraph 5
requires both systems to be used to announce the next
stop not more than 5 minutes before the train is
expected to stop (unless stops are less than two minutes
apart). It also requires PA to be used to announce
delays, diversions and emergencies.
On the face of it this implies two announcements are
necessary between each stop, one at each station
announcing destination and another just prior to arrival
announcing next stop. Regulation 4 doesn’t seem to be
satisfactorily worded in that it doesn’t indicate
whether an announcement has to be made once or
continuously – a train can dwell at a station for a long
time on occasions.
Our government likes to have more than one bite of the
cherry though. Not satisfied with producing regulations
it then issues guidance which is different from the
regulations. We therefore find the ‘guidance’ suggests
that when a train is stationary an announcement is made
announcing the stop and the next stop as well as the
final destination. So far as announcing next station
before arrival is concerned, the suggestion is made that
making it more than once is helpful when stations are a
long distance apart. However even the guidance
acknowledges that only ‘essential’ information is given
and that too much ‘might irritate other passengers’.
Fascinatingly, we learn that ‘too much’ information
includes describing catering facilities.
Having said all that, the RVAR is nothing to do with
European legislation and was an entirely home-spun
production, the detail having been produced by the
Department for Transport in conjunction with the
Disabled Persons Transport Advisory Committee, set up in
1985 to advise the DfT. Nor was the Disability
Discrimination Act 1995 the consequence of any European
legislative activity. If the way RAVR interpretation is
beginning to jar with the population at large, it isn’t
(for a change) the result of Brussel’s dictate.
But this is changing. Brussels wants Europe to be a
seamless travel zone by train and has introduced the
concept of the Trans European Network (or TEN, for
short). TEN includes a large number of lines within the
UK, basically all the inter-City routes and some others
for good measure. To ensure that interoperability is
possible, various Technical Specifications for
Interoperability (TSIs) are being issued that apply to
the whole of the TEN network and vehicles providing
train services along it.
A TSI concerning ‘Persons with Reduced Mobility’ was
issued on 21st December 2007 (regulation 2008/164/EC).
This came into force on 1st July 2008 and makes the
following requirements in relation to passenger
information made audibly.
4.2.2.8.3. Information (route description and seat
reservation)
The train shall be fitted with a public address system
which shall be used either for routine or emergency
announcements by the driver or by another crewmember who
has specific responsibility for passengers.
The system may operate on a manual, an automated or
pre-programmed basis. If the system is automated, it
shall be possible to suppress, or correct, incorrect or
misleading information.
The system shall be used to announce the destination and
next stop of the train, or on departure from, each stop.
The system shall be used to announce the next stop of
the train at least two minutes before the arrival of the
train at that stop. If the next station is less than two
minutes planned journey time away, the next station
shall be announced immediately following departure from
the previous station.
The spoken information shall have a minimum RASTI level
of 0,5, in accordance with IEC 60268-16 part 16, in all
areas. The system shall meet the requirement at each
seat location and wheelchair space.
The system shall be capable of giving announcements in
more than one language. (The choice and number of
languages shall be the responsibility of the Railway
Undertaking having regard to the clientele of an
individual train service).
If the system is automated, it shall be possible to
suppress, or correct, incorrect or misleading
information.
4.1.2.12. Spoken information
The spoken information shall have a minimum RASTI level
of 0,5, in accordance with IEC 60268-16 part 16, in all
areas.
Where provided, spoken information shall be consistent
with essential visual information that is being
displayed.
Where spoken information is not provided automatically,
an audible communication system shall be provided to
allow users to get information upon request.
It will be noticed that this information is crafted more
thoughtfully than RAVR, but nevertheless conflicts with
it. In consequence we now have “The Rail Vehicle
Accessibility (Interoperable Rail System) Regulations
2008” to contend with (these came into force on 7th
July. This document denotes that vehicles that operate
in the UK on the TEN (Conventional) network (about 70
per cent of UK track mileage) will be deemed to comply
with the new regulations if they had previously complied
with RVAR. New vehicles, though, must comply with the
new interoperability regulations. That should be fun for
staff and vehicle designers who operate both types of
vehicle, and potentially confusing for passengers.
However, existing vehicles must continue to comply with
the regulations in force when first brought into service
(ie RVAR) so the old wording will continue to apply to
most vehicles for some time to come.
Readers will all be anxious to know what a RASTI level
is, as this applies to the new regulations but not the
old ones. It actually stands for Rapid Speech
Transmission Index, and is a standard method of
determining the intelligibility of transmitted speech.
It is graduated between the values of 0 and 1, and a
value of 0.75 is regarded as excellent and 0.3 or below
as unsatisfactory. The EU, in plumping for a
suspiciously round 0.5, is asking for a quality
described only as ‘fair’, though for amplified systems
it may not be practicable to ask for better. A high
RASTI at the lowest practical volume would be a good
result.
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