As Chair of the ‘Bedfordshire Rail Access Network’, I was recently contacted by Network Rail as part of a public consultation into replacing the (inaccessible) station footbridge at Harlington station in Bedfordshire. Harlington station has four platforms, only two of these are scheduled for use by passenger trains and both of these are inaccessible due to the footbridge.
Their email, sent on 4th September 2024, began:
“We are contacting you today seeking comments as part of a public consultation process to replace the existing station footbridge at Harlington Station, Bedfordshire. Harlington Station is located towards the southwest of Harlington village centre. The station provides a rail link to several destinations, including Bedford, Brighton, Gatwick Airport, London Bridge and London St Pancras.”
The email went on to say:
“The footbridge at Harlington Station has been subject to ad-hoc structural repairs over recent years. The overall condition of the footbridge has deteriorated, and it is reaching the end of its life span.
It is proposed to construct a new stepped footbridge to the south of the existing footbridge. The footbridge will have features such as ‘warm to touch’ handrails, anti-slip surfacing, colour contrasting edges on each step and tactile paving.
The new footbridge will have stepped access only; however, it will have passive provision for lifts to be installed in the future. The existing bridge will be demolished after the new bridge is opened. The start and end dates of the works are yet to be confirmed.“
After receiving this email I contacted my BRAN colleagues, including wheelchair users and visually impaired passengers, who were as incredulous as I was that an inaccessible bridge would be replaced by a brand new inaccessible bridge. I responded to Network Rail on 18th September as follows:
“Thank you for emailing BRAN regarding your proposals at Harlington station.
Having spoken to the team, we must advise you that we are strongly opposed to the proposals set out in your email. It is inconceivable to us that you propose to replace an old inaccessible bridge with a new inaccessible bridge.
We believe your proposals are a breach of the Equality Act and do not see how the proposed project matches the requirements of the PRM TSI. Please advise why Network Rail seems to think differently.
When major station work is carried out, which the project you outlined clearly is, it must lead to accessibility. The passive provision for lifts is not accessible provision.
We look forward to hearing from you regarding the above and request that you keep us informed of any current or future plans at the station”.
Network Rail provided a holding response, before replying in full on 14th November as follows:
“Harlington footbridge is in need of renewal as the existing structure is approaching life-expiry. Unfortunately, the proposals for renewal do not include provision of step-free access at this time. I would like to take this opportunity to explain how this decision was taken.
We are fully aware of the need to comply with modern standards, in particular the Department for Transport (DfT) Code for Accessible Railway Stations and the Persons of Reduced Mobility (PRM) NTSN. As part of the development of the renewal project, a Diversity Impact Assessment (DIA) was completed.
Network Rail supported the Train Operating Company, Govia Thameslink, and local community in their application for funding as part of the DfT’s Access for All (AfA) programme. Unfortunately this was unsuccessful.
Access for All gives priority to schemes which will benefit the greatest number of Persons of Reduced Mobility (PRM) as identified in the DIA. This helps to ensure that public funds are used most effectively and have the greatest possible impact. The decision not to provide funding at Harlington under the AfA programme means that the renewal scheme cannot afford to install lifts as part of their work. Instead passive provision will be made which will enable lifts to be fitted in future, should such funding be available.
Appendix B of the PRM NTSN allows for passive provision for lifts to a footbridge when the average daily footfall is below 1,000 passengers per day. This is the situation at Harlington. By providing passive provision for lifts the renewal project delivers a legally and regulatory compliant asset. The renewed bridge will improve accessibility offering at Harlington station for some protected characteristics while also making passive provision for future improvements for passengers with reduced mobility.
I appreciate that this is disappointing to those who are using the station now, but we must ensure that our funding is used in a way that achieves the best possible benefit for the maximum number of passengers.
Luton Airport Parkway is currently the nearest accessible station to Harlington but is around a 13 mile journey for passengers. However, Flitwick station, which is around four miles from Harlington has been allocated funding for a fully accessible bridge through the Access for All programme. Once complete, this will provide a network benefit to passengers in the Harlington area. The collective interventions at Flitwick and Harlington offer a betterment in accessible provision in the local area, whilst also taking steps to enable future accessibility enhancement at Harlington“.
It took me some time to find ‘Appendix B’ within the ‘Persons with Reduced Mobility National Technical Specification Notice’ (PRM NTSN). You can find it below and it does permit the ‘passive’ provision for lifts – i.e. not installing them – when the passenger numbers of any station are below 365,000 a year – and there is an accessible station within 50km of the station. Some get out clause this!
This does not mean that lifts cannot be installed at stations with passenger numbers less than 365,000 a year, as successful bids for ‘Access for All’ funding for Llanelli 274,00 and Ulverston 257,000 passengers a year indicate, but it does set a benchmark for inaction.
While Appendix B has been in place for some time (it has been present in the EU regulation since 2014) and has been transferred over to UK regulations since we left the EU, there have clearly been some attempts to remove this clause as the red lines in a draft consultation version of the PRM NTSN from August 2022 shows.
How many stations does this Appendix B impact? There are around 2,570 railway stations across the UK. Of these, only 909 (from the ORR passenger estimates 2022/23) have more than 365,000 passengers a year. Therefore this clause permitting inaction, what the rail industry terms ‘passive provision’, potentially affects around 1,660 stations across the UK. Vast swathes of the UK will continue to have inaccessible public transport while this clause remains in place.
While I understand the prioritising of busier stations first, this 365k cut-off is setting a very low bar and I think the public will be shocked that old inaccessible infrastructure is permitted to be replaced with brand-new inaccessible infrastructure via this legal loophole. This clause should be removed and any new rail infrastructure projects must be fully accessible.
We have to be more ambitious than this and fundamentally change the culture within the rail industry that still sees accessibility as a ‘nice to have’ rather than a right. We must have a legally binding roadmap of railway station access improvements and mandate level boarding for all future rolling stock procurement.
Julian Vaughan
15th November 2024
Further Reading:
NTSN PRM 1 January 2021
Access for All Audit
https://julianvaughan.blog/2024/09/10/uk-railways-access-for-all-audit/
A decade of step-free delay
https://julianvaughan.blog/2024/08/09/a-decade-of-step-free-delay/
Julian Vaughan 
4 thoughts on “Step-free and ‘Appendix B’”