Application for exemption from train protection duties: Paddington to Heathrow Airport Junction

Date of publication
Closing date

Five rail companies have applied to ORR for exemption from the law which requires the provision of automatic train protection.  The application relates to certain trains operating between London Paddington Station and Heathrow Airport Junction, covering about the first 12 miles of the Great Western Route.  This consultation invites the public or any party to express a view on the application: in making our decision ORR will consider all views. Full details are set out in the documents linked to this page.  If you wish to make comments, please contact us at .

The deadline for comments is 2 August 2019.

The applicants are:

  • Network Rail Infrastructure Limited
  • First Greater Western Limited
  • Crossrail Limited
  • Heathrow Express Operating Company Limited
  • MTR Corporation (Crossrail) Limited

There is currently an exemption in place for Class 345 trains operated on the same route, granted by ORR in 2016.  Details of this can be found here:

The new application seeks to extend the time permitted for the exemption until 31 December 2023; to shorten the length of railway included, so that the Heathrow spur is no longer exempted; and to widen the scope of the exemption to cover in addition Class 387 rolling stock which will replace the current Heathrow Express trains.

The Railway Safety Regulations 1999 require infrastructure managers and train operators only to permit the operation of trains with train protection equipment fitted.  This is equipment which can stop a train if it passes a red signal, or if it approaches a red signal at too high a speed, or drives too fast.  Where it is reasonably practicable to fit automatic train protection (ATP) this must be used.  ORR may, at our discretion, grant an exemption to this law, and we are obliged to conduct a public consultation to assist our considerations.

A version of ATP is fitted to the track between Paddington and Heathrow, and to the trains currently running services to the airport.  A new version of ATP, known as ETCS, is being installed in the track, but may not be completed until the end of 2023.  ETCS is fitted to the new classes of train, but the applicants wish to operate without also fitting the older ATP to the trains.  They propose to continue relying instead on their enhanced deployment of the Train Protection and Warning System (TPWS) which also protects trains from passing red signals, but without the full over-speeding prevention functionality of ATP systems.  Their detailed proposals and safety arguments can be found in the application.

Responding to this consultation

If you wish to make comments, please contact us at The deadline for comments is 2 August 2019.

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