Network Rail plan to erect over 2,000 microwave radio masts, one every four or five miles along every railway line in the UK.

Each of these masts will be at least 33 metres tall - as high as a 12-storey block of flats.

Because of a legal loophole, they don't need planning permission, even in Areas of Outstanding Natural Beauty and Conservation Areas.

Network Rail say the masts are needed for safety reasons. To support this claim, they cite the Cullen Report on the Ladbroke Grove crash and the Joint Uff/Cullen Report on Automatic Train Protection (ATP). But both Reports contain compelling evidence against the masts.

The Cullen Report warned that fitting ATP on top of TPWS (Train Protection and Warning System, which is already installed throughout the UK) would bring negligible safety benefits at enormous cost.

Yet Network Rail now propose to install ERTMS, a form of ATP that requires microwave masts, at a budgeted cost of £4,280 million. A report published by the Health and Safety Executive estimates that ERTMS will prevent no more than 16 fatalities in 40 years, at a cost of £267.5 million each. According to the Cullen Report, the same money spent on road improvements could prevent 42,800 fatalities, at a cost of just £100,000 each.

And Network Rail has chosen an unproven, non-standard version of ERTMS, flouting the Joint Uff/Cullen Report, which recommended a standardised version (Level 1) that does not require masts.

In pioneering this grandiose scheme, Network Rail are betting huge amounts of public money on unproven technology, in return for virtually no safety benefit and minimal, and entirely speculative, performance gains (Railway Safety's best guess is a 10% capacity increase, but a report published by the Health and Safety Executive has cast doubt on this estimate, pointing out that TPWS has reduced capacity.

Network Rail also say that the masts are necessary because of an EU Directive on interoperability, which is intended to allow trains to travel freely from one country to another.

The original Directive has been extended to require all railways in the EU to implement a computer-based control system called the European Rail Traffic Management System (ERTMS). ERTMS will allow trains to be controlled from regional computer centres, with no need for signallers or drivers for normal operations. Network Rail say that the new masts, which use a technology called GSM-R (Global System for Mobile communications - Railway), will provide the radio communications required by ERTMS; they will also replace the existing driver-to-signaller radio systems.

No other EU country has implemented ERTMS Level 2. Italy plans to use it on new High Speed Lines only, and neither France nor Germany have firm dates for implementing it at all.

The only UK line that will be exempt from ERTMS and GSM-R is the Channel Tunnel Rail Link, which has to be compatible with the Channel Tunnel itself, which uses non-GSM-R technology.

So the only section of rail for which the UK has sought exemption from the EU interoperability Directive is the only section of UK rail that interoperates with European railways.

If the Government can't or won't divert Network Rail from this folly, they should at least prevent them from defacing the countryside with these enormous masts. Much smaller ones are available, down to 5 metres. More of them would be required, thus increasing the cost, but the additional expenditure would be trivial in relation to the cost of the whole project - 'only' £171 million (less than 5% of the total budget) will be spent on the GSM-R network (including masts). And there are already proven alternatives that require no masts at all.

Planning permission

Network Rail claim that erecting these masts on their own land falls within the "permitted development" they are entitled to under Part 17(A) of the Town & Country Planning (General Permitted Development) Order 1995, or GPDO, which concerns 'Railway or light railway undertakings'. Permitted developments do not require planning consent. This privilege dates back to the 19th century, long before the advent of mobile telecommunications. There is no limit on height under Part 17(A). The GPDO also contains specific provision for telecommunications masts: Part 24 (Development by Telecommunications Code System Operators) and Part 25 (Other Telecommunications Development) of the GPDO, which covers other mobile phone operators and limits them to a mast height of 15 metres unless they get planning consent. Network Rail argue that these provisions do not apply to them.

Article 4 of the GPDO can be used to restrict or prevent permitted development, but councils are very reluctant to use it, because they may have to compensate the developer; it is used only in exceptional circumstances, eg in Conservation Areas or for buildings with Grade 1 listing. South Hams District Council served an Article 4 Direction on Network Rail to prevent them putting a GSM-R Mast in front of Totnes Castle (Listed Grade 1*). Paragraph 46 of Planning Policy Guidance 8: Telecommunications states that "where a particular rural or urban location seems likely to attract obtrusive or inappropriate telecommunications development which would seriously threaten amenity, the Secretary of State will give sympathetic consideration to directions submitted for approval."

There are several reasons why Network Rail may be wrong in its interpretation of the existing GPDO, which are explored in an excellent section of the Planning Sanity website.The author argues that, since Part 17(A) applies only to development "required in connection with the movement of traffic by rail", that development cannot be used, wholly or partly, for any other purpose. He then cites evidence that Network Rail plans to use the GSM-R masts for "customer information systems, as well as for more general business needs" - neither of which is directly relevant to the movement of rail traffic. The author also argues that Part 17 is in violation of Article 6.1 of the European Convention on Human Rights and Fundamental Principles.

Another, and maybe even more telling, reason for disallowing Network Rail's claim to immunity under Part 17(A) has been pointed out by Patsy Calton, MP for Cheadle, in Parliament and on her website. In a written reply to a parliamentary question, Alistair Darling, Secretary of State for Transport, revealed that the masts erected 18 months ago on the West Coast Main Line are still not operational - indeed, there is no prospect of them becoming fully operational until 2015 (see Delays? So what!). According to Mr Darling, they don't even support GSM-R voice traffic yet. How then, she argues, could Network Rail claim that they were "required in connection with the movement of traffic by rail"? Mrs Calton has written to her Council's Planning Department to ask that enforcement action be taken against Network Rail for erecting a GSM-R mast in her constituency.

Indeed, even if Network Rail expect to be able to implement simple driver-to-signaller voice radio in the near future using GSM-R, it is certain that they don't need so many and such tall masts for that purpose (see GSM-R masts: why so big, and why so many?). It is clearly illegitimate for Network Rail to claim permitted rights for any mast that will not be used operationally for more than a fraction of its capacity for nearly 10 years.

The Planning Sanity website referred to above also argues that, even if Part 17, which covers railway infrastructure in general, is applicable, Part 25, which specifically covers microwave antennae, should take precedence.

Nonetheless, Network Rail, backed by the Government, insist that the masts are to be considered as railway infrastructure and not as telecommunications masts. Just how principled this position is can be judged by the facility with which they reverse it when it's convenient for them to do so (see below).

The Government is reviewing the planning process, in particular Permitted Development Rights. The main purpose is to speed up planning decisions by extending these rights, but it does seem possible that Network Rail's 'rights' under Part 17(A) may be curtailed. A report, Review of Permitted Development Rights, is available from the Office of the Deputy Prime Minister (it's a 976-kilobyte PDF). We have put relevant excerpts on this web page.

However, even if the Government does change the law in time to prevent the erection of 2000 33-metre masts, it would be a Pyrrhic victory if it resulted in the erection of twice or three times as many 50-foot (15-metre) masts in their place. In any case, there seems to be no good reason why the masts have to be so big and/or numerous - see righthand column.

EU Directive 2001/42/EC requires an Environmental Impact Assessment (EIA) to be carried out for major projects, to ensure that the environmental implications of decisions are taken into account before they are made. This should entail the publication of a report and a public consultation exercise. In the Guidance on EIA (available here as a 400-kilobyte PDF), item 3.13 in the checklist is: "Is the landscape or townscape of the area that may be affected by the Project described, including any designated or protected landscapes and any important views or viewpoints?" Directive 97/11/EC, which updates Directive 85/337/EEC (a consolidated version is available here as a 78-kilobyte PDF), lists projects requiring EIAs in Annex I. Item 7(a) of that list is: "Construction of lines for long-distance railway traffic".

Clear enough, you might think. We wrote to the Environmental Assessment Branch of the Office of the Deputy Prime Minister (ODPM), which is responsible for environmental assessments, to ask whether the EIA had been completed and, if so, where we could get a copy of the Report and details of the public consultation exercise that took place. Here was the ODPM's reply:

In regards to environmental impact assessment, erection of telecommunications masts are not projects that come under the Directive 85/337/EEC on "The assessment of the effects of certain public and private projects on the environment" as amended by Directive 97/11/EC. UK EIA Regulations do not, therefore, require EIA for such projects.

There we have it in all its Orwellian elegance: as far as the GPDO is concerned, GSM-R masts are not telecommunications masts but part of the railway infrastructure; as far as Directive 97/11/EC is concerned, they are not part of the railway infrastructure but telecommunications masts.

Even the ODPM seems to be ignorant of the extent of Network Rail's powers. In Paragraph 5 of the evidence submitted to the All Party Parliamentary Mobile Group in April 2004 (click here for the document in Word), the ODPM boasts of its:

...national policies for the protection of the countryside and residential areas, in particular our National Parks, Areas of Outstanding Natural Beauty, conservation areas and Sites of Special Scientific Interest. The installation of any communications mast in such areas, and of a mast of more than 15 metres in height elsewhere, is subject to a full planning application. [Our emphasis]

The last sentence is just not true, of course - because of their privileged position, which the ODPM supports, Network Rail can, and do, erect masts of any height, anywhere they want, regardless of local concerns (or maybe the ODPM has been taken in by its own casuistry and believes that they really aren't telecommunications masts at all).

There is another legal avenue that applies to Areas of Outstanding Natural Beauty: Section 85 of the Countryside and Rights of Way Act 2000 states that "a relevant authority shall have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty". "Relevant authorities" include statutory undertakers (which includes Network Rail) and local authorities. This is in Part IV of the Act. The Catch 22 with that legislation is that, according to DEFRA (the Department for Environment Food and Rural Affairs, "whether an authority is in compliance or not would be a matter for a Court to decide" - DEFRA itself does not get involved.

Safety: the Cullen Report

Safety is at the very heart of Network Rail's - and the Government's - justification for these masts. In the House of Commons on 21 May 2004, Keith Hill, Minister of State in the Office of the Deputy Prime Minister, described the masts as "Network Rail's new safety system", and went on to say that their introduction "is primarily safety driven. It will implement a key conclusion of the Cullen investigation into and report on the Ladbroke Grove rail accident...."

The Cullen Report's support for a nationwide communications system is the first plank in Network Rail's case for the masts. They call it "a key recommendation" - in fact, it's number 51 out of 89 recommendations, of which 41 were designated as 'key'.

However, if you read the Cullen Report itself, a rather different picture emerges from the one Network Rail paints.

First of all, all the trains involved in the Ladbroke Grove crash (which took place on 5 October 1999) already had in-cab radio systems.

In fact, the train that caused the crash was equipped with CSR, and Lord Cullen concluded that, if it had been used effectively, it would have prevented the accident! He blamed Railtrack's management for failing to train signalmen to use it properly in an emergency. His only criticism of it was that it was only installed in the south of England.

A similar combination of effective technology and incompetent usage occurred with the Southall crash - the train that caused that accident had, not one, but two safety systems installed: the basic Automatic Warning System, which sounds a buzzer in the cab when a warning signal is passed, and BR-ATP, Railtrack's version of the more advanced Automatic Train Protection (see below), which applies the brake if the driver fails to stop. They did not prevent the crash because neither was working at the time - the AWS because it was broken and the ATP because the driver was not trained to use it so it was switched off.

The Cullen Report also makes favourable comment about First Great Western's experiment with issuing conventional mobile phones to its drivers and conductors.

We have extracted the relevant passages, which can be read on this web page. Alternatively, you can download a PDF copy of the full Report from here. However, it is three megabytes in size.

It's important to remember that rail is already the safest form of transport by a wide margin. Click here to download a PDF article by Norman Bradbury (65 kilobytes) published in Railwatch, November 2002. It shows that (measured by fatalities per 100 million kilometres travelled) rail travel is over 27 times safer than road travel.

Here are four quotes from a report published by Railway Safety and the Strategic Rail Authority in April 2002, called ERTMS: Towards a Better, Safer Rail System, which can be downloaded from the Strategic Rail Authority's site as an 808-kilobyte PDF file (ERTMS stands for European Rail Traffic Management System, of which GSM-R is part, and ATP means Automatic Train Protection):

As TPWS [Train Protection and Warning System, which is already operational on all UK tracks] significantly mitigates ATP-preventable risks [preventing over 80% of them], the relatively small additional risk reduction achieved by ERTMS (once TPWS is installed) appears not to be justified purely as a safety investment.

ERTMS... will address the majority of ATP-preventable risk. This equates to a maximum estimated saving of 83 equivalent lives over the next 40 years. By comparison, UK road deaths are currently running at approximately 66 per week [our emphasis].

On this basis, the approximate capital cost per equivalent fatality avoided is between £75 million... and £45 million... over 40 years.

This means that there will be other potential safety investments, on and off the railway, which deliver much greater safety benefits [our emphasis].

However, the Health and Safety Executive, in Train Protection - Review of economic aspects of the work of the ERTMS Programme Team, published in 2003 (a 1.5 megabyte PDF), gives an even lower estimate of the safety benefit of Network Rail's preferred version of ERTMS: "Our own estimate is that the risk, at today's traffic levels, with TPWS and TPWS+ but without ERTMS, is one fatal ATP-preventable accident in about ten years" [our emphasis]. With an estimated four fatalities per accident, this would work out at £267.5 million per fatality over a 40-year period. (TPWS+ is an up-rated version of TPWS, which works at higher speeds.)

The same report criticises the ERTMS Programme Team for ignoring one "politically important" risk: "namely, that of an ERTMS-induced multi-fatality accident in the early days of ERTMS".

If the money is to be spent directly on rail safety, it would be far better spent on track maintenance and staff training: of the four recent major crashes, two (Potter's Bar and Hatfield) were caused by poor track maintenance, and the other two (Southall and Ladbroke Grove) were primarily caused by poor training resulting in the failure to make use of the technology already available, which if it had been used would have averted both accidents.

If saving the most lives for the money spent is the objective, the £4.28 billion Network Rail is planning to spend on ERTMS and the GSM-R network (let alone the amount it would probably end up spending) would be far better spent on improving the reliability, punctuality, comfort, and convenience of services, and subsidising fares more heavily, in order to attract road-users back to rail transport (thus cutting their risk of death in transit by more than 95%). No doubt regular rail users would also appreciate more reliability, punctuality, etc, plus lower fares!

Unfortunately, Network Rail is squandering so much money on ERTMS and other grandiose schemes (all justified in the name of safety, though rail is by far the safest form of travel already) that money earmarked for road improvements (many of them genuinely safety-related) is no longer available. An article on the subject, called Roads facing axe to meet rail bill, was published in the Daily Telegraph (1 April 2004).

Yet road improvements give a far higher pay-back in terms of safety - in the report ERTMS: Towards a Better, Safer Rail System (see above), Railway Safety and the Strategic Rail Authority state, in a footnote, that the DTLR's (Department of Transport for Local Government and Regions) 'appraisal value' for cost per road fatality avoided is £1.14 million, "although the actual spend per life saved on local authority highway safety schemes is understood to be very much lower".

In fact, according to the Commission for Integrated Transport, the amount spent on road safety is less than a tenth of this 'appraisal value':

The Ladbroke Grove Rail Inquiry, Part 2 Report includes a "Joint statement of experts on risk management" which records that several experts observed differences in government planned and contemplated expenditure on road and rail safety: the actual expenditure to prevent a road fatality is around £0.1 million [our emphasis]; and the cost per fatality avoided by fitting TPWS (Train Protection and Warning System) is about £10 million.

CfIT's initial assessment report on the 10 Year Transport Plan, Part 7, 22 May 2002

According to a news release by the European Road Assessment Programme, called Cutting road deaths is cheap - but we can't do it, say councils, the cost to prevent one road fatality in many areas of the UK is just half that figure, at £50,000 or less - but no money is available.

Network Rail is clearly aware of, but not in the least abashed by, this disparity. In fact, in a breathtaking display of spin, it uses road-users' far higher fatality rates to justify the adoption of ERTMS Level 2 (which requires GSM-R) rather than Level 1 (which the Uff/Cullen Report recommended): it argues that Level 2's (hypothetical) increase in capacity would allow it to attract more road-users back to the railway, thus saving between 300 and 700 road fatalities over 40 years. The Health and Safety Executive Report cited above disputes these figures: "Our own estimates suggest that the EPTFR (ERTMS Programme Team Final Report) overestimated the increase in road fatalities, for their assumed lost of rail capacity, by a factor of four or five."

In any case, the 36,000 road-users' lives that could be saved by spending the money directly on road safety don't figure in the calculations at all.

Replacing current in-cab radio systems

Network Rail claim that their existing radio systems are obsolete and must be replaced as soon as possible. They are getting old, it's true, but they're not obsolete yet by any means - when necessary, Network Rail always seem to find that their useful lives can be prolonged).

As far as we know, Network Rail's first attempts to replace them with digital technology was a short-lived radio system called DART. This is the first reference we could find to it:

...we are developing a new system called DART (Digital Advanced Radio for Trains). Last year a £13 million contract was awarded to Siemens UK to develop the system hardware.

Memorandum by Railtrack (RS 01), 9 December 1998

More information is given in the 1998 Network Management Statement:

We have...launched a project to develop a digital radio system, initially to replace NRN but with the capability also to replace CSR where the additional performance of a 'secure' system is required.

The International Union of Railways (UIC) has led development of a new international train radio based on digital cellular telephony standards. We have been participating in this project and we have decided to proceed with a digital system which we have called DART (Digital Advanced Radio for Trains), using the public cellphone network as the radio bearer.

DART will involve working with the selected network operator to provide the required coverage levels along the lines of route where it is implemented (including tunnels and cuttings where the 'secure' mode is required). This will have the secondary benefit of giving much improved performance to other users of the selected network travelling by train. Certain 'special' features also need to be provided to ensure emergency calls get appropriate priority and that train drivers cannot be called by unauthorised persons.

It is planned to have a pilot DART radio system operational during 2000. Once proven, the system is planned to be used to replace the existing Cab Secure Radio equipment in Scotland and currently used to support the Strathclyde Manning Agreement. The benefits of providing a good quality train radio have been outlined in a number of accident inquiry reports. DART has the potential to provide such a radio system in a cost-effective manner.

Network Management Statement 1998, page 60-61(3.1 megabyte PDF)

How eminently sensible: sharing existing mast capacity with one or more mobile phone operators in order to minimise wasteful overlap, and so provide a modern in-cab radio system "in a cost-effective manner", while extending mobile phone coverage to rail passengers.

It was too good to last, of course: just a few months later, DART had been unceremoniously dropped. This was alluded to in the Cullen Report (paragraph 12.29): "Counsel for First Great Western rightly submitted that it was most unfortunate that there was still no national system of radio communication between trains and signallers. Counsel pointed out that First Great Western had pressed for a modern radio system. In April 1999 Railtrack had cancelled the DART project (to introduce such a system nationwide) without explanation. It was common ground that such a system is desirable and,...there appeared to be no insurmountable technical difficulty."

The nearest we've been able to find to an explanation for the scrapping of DART is this:

During the course of 1998/99, we established that the National Radio Network (NRN) can be maintained as an effective operational radio system until about 2008, which is about 4 years longer than previously envisaged. In addition the tendering process has shown that use of the public cell phone network for our operational railway purposes is not cost effective in the context of renewal options. We have therefore decided not to proceed at present with Digital Advanced Radio for Trains (DART). As such, we are re-evaluating options for the long-term renewal of NRN and Cab Secure Radio (CSR). We intend to discuss the options for developing a modern digital based approach to meeting the radio requirements for the railway with the industry during the course of 1999/2000.

The Annual Reconciliation Statement, Report of Progress Against Plans Set Out in the 1998 Network Management Statement, Network Rail, July 1999 (416 kilobyte PDF)

The second sentence ("the tendering process has shown that use of the public cell phone network for our operational railway purposes is not cost effective in the context of renewal options") is almost impenetrable, but the implication is that Network Rail did not enjoy the experience of cooperating with external organizations such as mobile phone operators.

Network Rail is, apparently, notorious within the mobile phone industry for its stand-offishness and "not invented here" syndrome. Given the Government's efforts to force mobile phone operators to cooperate by sharing masts, it is outrageous that Network Rail should be allowed to withdraw from cooperation without explaining its reasons in detail.

In the Cullen report, it was stated that "Railtrack was developing a national radio project in a form of CSR which was European compatible. This was for all passenger lines and that was being looked at as a matter of urgency." This new radio system was almost certainly GSM-R.

The GSM-R network started as a straightforward digital replacement for the existing analogue in-cab radio systems, as suggested in Lord Cullen's recommendation. In a document published in January 2001 (available here as a 1.3 megabyte PDF), Railtrack estimated that they would require 1425 GSM-R masts at 12-kilometre intervals - roughly the same number as they have already. The document states that "Where possible existing NRN and CSR sites will be re-used."

So far, so sensible. However, within a year the GSM-R radio project had been swallowed up in the grandiose ERTMS Level 2 project:

The Railtrack GSM-R network is currently being developed as a replacement for existing radio systems and is currently authorised (and funded) to support the voice application only. Support for ETCS [European Train Control System, part of ERTMS ] data would represent an enhancement to the GSM-R network and would require separate, additional funding to be made available.

ERTMS Program Team [EPT] Final Report April 2002 (2.1 megabyte PDF).

Modifying the GSM-R network to support ERTMS not only costs more, it also requires more masts, as the same document makes clear:

The radio signal strength for ERTMS data is higher than for voice and would require 10-20% more base stations along the line. The National GSM-R Network is being planned to have the signal strength for data confined to the high speed TENs Lines, although agreement on funding has yet to be reached. The rest of the network is currently only planned to support voice, and for ERTMS to function satisfactorily, the signal strength for data should be provided wherever ERTMS Level 2 is required.

Because of Network Rail's subsequent decision to extend ERTMS to all UK lines, not just the three high-speed lines originally envisaged (the west and east coast main lines and the Paddington-Bristol/Cardiff line), the number of extra masts required went up by 40% rather than the 10-20% estimated here. That, of course, is not how Network Rail or the Government explained it - here's an excerpt from Hansard (31 March 2003):

Mr Jamieson: I understand that Network Rail is upgrading its analogue radio systems network of around 1,400 telecommunications masts to a national digital network of approximately 2,000 masts. The increased number arises from the extended coverage of the new system across the entire rail network, including all tunnels and cuttings.

The truth is that virtually all the masts in new locations are dictated by the demands of ERTMS, not the GSM-R in-cab radio system (which, according to Network Rail, could be supported by the same number of masts as the existing CSR and NRN network).

The additional height of the masts is also dictated by the demands of ERTMS, since a voice radio system based on GSM should require both fewer and shorter masts.

The explanation is, apparently, that "the Network Rail system has been designed to facilitate contact not just to the adjoining cells, but to two cells in each direction. This provides a 'failsafe' safety factor so that the system will continue to function even if one transmitter is out of action, but the consequence of this is that taller masts are required – the proposed masts are typically 30 metres or more in height, and are to be installed at appropriate points along all main lines throughout the country." Such a degree of redundancy can only be warranted for safety-critical data communications required for automatic train control - that is, ERTMS. For driver-to-signaller voice communication, some redundancy may be required in very congested sections of track with multiple points and signals - but certainly not throughout the country, and certainly not to that degree.

Only 188 GSM-R masts had been erected by March 2004, most of them on the West Coast Main Line. None of them is being used for GSM-R voice communication. According to Alistair Darling, Secretary of State for Transport, in a letter to Patsy Calton MP, GSM-R hasn't even been tested in the UK yet - trials are scheduled for the end of 2004. It is hoped that the radio system will be operational on some lines by 2006. Some of the masts are being used now for yet another Network Rail radio system called Interim Voice Radio System (IVRS). A Marconi press release explains that IVRS is "a GSM-R solution, supplied by Nortel Networks, to support Railtrack's existing radio system" - presumably NRN.

So the masts won't even be used for GSM-R radio communication until 2006. And they won't be used for ERTMS (the reason for almost all the new ones) until 2015 at the earliest. By then, GSM-R will be at least as obsolete as CSR and NRN are now.

EU Directive

Network Rail claim that they are obliged to introduce a GSM-R network covering all their track by a European Union law (Directive 96/48).

Directive 96/48/EC has been incorporated in UK law by Statutory Instrument 2002 No 1166, The Railways (Interoperability) (High-Speed) Regulations 2002. Relevant documents can be found on the Department for Transport website (in HTML, PDF, and Word).

The GSM-R network is mandated by the European Union for so-called TEN routes, and also for lines that cross or share track with TEN routes. TEN stands for Trans-European Network, a term first used in the Treaty of Rome Article 129b to cover a wide variety of networks, including road, ferry, and communications. The term is not used in Council Directive 96/48/EC - the expression "high-speed lines" (defined basically as lines equipped for speeds of 200 kph or more - that is, 125+ mph) is used instead.

A similar Directive on the interoperability of the conventional, ie non-high-speed, trans-European rail system came into force in April 2001 (Directive 2001/16/EC).

There are four TEN routes in the UK mainland: the Channel Tunnel Rail Link and the part of the Channel Tunnel that falls within UK jurisdiction, the West and East Coast Main Lines, and the Great Western Main Line between London and Bristol/Cardiff.

In the Treaty of Rome, and in the Directives themselves, 'interoperability' meant what most people would understand by the term - that is, the ability for trains from one EU country to run on tracks in another. Both Directives are summarised on this EU Web page. Here is a quote from it (our emphasis):

The objective of these two directives is to narrow down the divide so that international trains can provide a better, completely safe service. when they change national networks

Here's another quote from the home page of the European Rail Traffic Management System:

Over the past decade, industrial giants and European governments have strived to attain rail interoperability, so that trains can cross borders without stopping.

Indeed, the standard letter sent by Network Rail to notify residents of a planned mast states that the purpose of the European directive is "to ensure that trains can safely travel from one country to another".

Increasingly, however, 'interoperability' is construed as 'standardisation', regardless of whether any cross-border traffic will ever occur. The benefits of interoperability in this sense, the EU believes, will come from "more open, competitive procurement".

However, the team responsible for ERTMS implementation in the UK clearly aren't interested in such savings. "To those rail pundits who advocate buying standard ERTMS products 'off the European shelf', the ERTMS team have a simple response - not just yet!" This comes from the December 2003 issue of ERTMS news, available as a 160KB Acrobat file from the SRA's website.Clearly, it would be more sensible to say "not just yet" to ERTMS! Fairly typically, the file name, ERTMSNewsletterJan03.pdf, is somewhat misleading! Here's another very worrying quote from the ERTMS team:

Level 2 [of ERTMS, the version Network Rail is opting for] is still being developed and tested throughout the EC on pilot lines. Economic viability, standards development and ownership, certified product availability and funding are all areas currently under discussion at European level.

The Health and Safety Executive report cited above (Train Protection - Review of economic aspects of the work of the ERTMS Programme) also talks of "the dangers of a British ERTMS which is so different from continental design that many supply-chain benefits are lost".

So Network Rail, by pioneering this technology, is throwing away its one possible advantage to the UK - "more open, competitive procurement" for standardised products! Have they learnt nothing from the WCML modernisation programme?

The standards applying to TEN routes are broken down into a number of areas or sub-systems, including rolling stock, infrastructure, maintenance, etc; the sub-system under which GSM-R falls is control-command and signalling. For each sub-system, there is or will be a Technical Specification for Interoperability (TSI).

It is possible to gain 'derogation' (ie exemption) from one or more provisions of any TSI. However, derogation from one provision does not in itself entail derogation from any other provision.

It is also possible to apply for derogation on the grounds of cost. The budgeted cost of the GSM-R network itself is £171 million (Supplementary Information to the 2000 NMS, page 24 - see above), but the primary reason for implementing it (rather than a simpler, cheaper, less intrusive alternative) is that it also forms the infrastructure for ERTMS (see above). ERTMS is currently (May 2004) budgeted to cost £4.28 billion. The Strategic Rail Authority is distinctly tepid about ERTMS's contribution to safety (see above) and is also dubious about the operational performance gains that ERTMS is supposed to bring (the SRA regards its "lack of capacity and resilience as a major technical risk").

Has Network Rail, or the Department for Transport, sought exemption from the control-command and signalling TSI (Technical Specification for Interoperability)?

The answer is "Yes", but only in respect of one UK line - and the one line that is exempt is (believe it or not!) the Channel Tunnel Rail Link, because it has to be compatible with the Channel Tunnel, which itself uses a non-GSM-R signalling system. This extraordinary fact appears on the Strategic Rail Authority's website. A written answer from the EU to Caroline Jackson, MEP for the South-West, confirms it: the only section of rail for which the UK has sought derogation from European railway interoperability standards is the only section of UK rail that interoperates with European railways.

In Clause 7 of the Regulatory Impact Assessment (also on the DfT website) it is stated that:

It is important to note that the Directive does not require works to comply with the TSIs to be undertaken; the obligations only arise when projects to build new high-speed lines, or to upgrade them for high-speed, are undertaken.

Since all the UK TEN lines have been high-speed routes (ie capable of handling speeds of 125mph and above) for quite a long time, another question is: what's forcing Network Rail to comply with the TSI now?

Here's a quotation from an excellent article called ERTMS: can it be made cost-effective?, published in the July 2004 issue of Modern Railways:

Up here in our little offshore island, where interoperability is not a practical issue, there is a tendency to assume that all the European railways are mad keen for ERTMS. They are not.

DB (German Rail) has taken the line that ERTMS brings no domestic benefit so that if European law decrees its fitment, Europe can pay. According to informed sources, the head of SNCB (Belgium Railways) described ERTMS as 'developed by subalterns, with no leadership, no business case and no migration strategy'.

According to the December 2003 issue of ERTMS news (see above), Italy plans to use Level 2 ERTMS on new high speed lines only, and neither France nor Germany have firm dates for implementing it at all. They obviously have more sense than to pioneer an unproven committee-designed technology on this scale! Only Austria and Bulgaria are said to have implemented Level 1 (a simpler version of) ERTMS.

If the EU really did intend to enable all trains in all countries to operate on all tracks, the costs involved would be staggering: the 'loading gauge' used varies from country to country, and the UK in particular is different from the others; in fact, the UK is exempt from the TEN loading gauge standards. ("The railway loading gauge is a series of height and width profiles above the rail tracks that govern the physical dimensions of a railway vehicle" - source: Highways Agency Guide to Freight.) Continental rolling stock is taller and (in the case of freight wagons) wider than UK rolling stock, and British platforms are much higher than the continental equivalent. Many of Britain's canopies, overhead power supplies, bridges, tunnels, etc, and all of our station platforms, would have to be replaced or modified to accommodate standard continental rolling-stock, while passengers on UK trains in Europe would have to jump up or down to get on or off at stations.

In any case, trains couldn't get safely from one side of the Channel to the other by rail, since their new GSM-R technology wouldn't work on the Rail Link or in the Channel Tunnel itself.

GSM-R and alternative technologies

Network Rail claim that the new network has to be based on GSM-R technology. But GSM-R does not necessarily require masts (let alone 33-metre masts): other, less obtrusive, technologies may be used.

One from the same manufacturer, Siemens, is called the "leaky feeder cable" or 'Euroloop'. On their website Siemens say that the leaky cable works under water, under snow, and under dust. London Underground and the Severn Tunnel have used leaky cable for years, as have the Swiss. Network Rail stated to the Tarka Action Group that leaky cable is a viable alternative system after all, which could be used instead of masts along the Tarka Line.

The other GSM-R-compatible solution uses satellite technology. Several GSM-over-IP (Internet Protocol) implementations are available, and satellite links can (and do) carry internet traffic (see below), so it would not be difficult to interconnect the existing GPS satellite system with GSM-R.

However, the European Union is creating its own satellite network, called Galileo, which is specifically intended to link-up with ERTMS (particularly the European Train Control System component). According to the section of the Galileo website devoted to rail applications, "The introduction of satellite navigation within the ETCS/ERTMS will... contribute to increase the performance on the high-density line[s] and lower the cost on low density and regional lines."

Galileo uses 30 satellites, distributed over three planes in Medium Earth Orbit, "which ensures a uniform performance both in terms of accuracy and availability." "Unlike GPS, it will be possible to receive Galileo in towns and in regions located in extreme latitudes." Galileo is scheduled to offer an operational service from 2008 onwards - that is, at least seven years before ERTMS becomes operational in the UK.

But both have disadvantages, according to Network Rail (who obviously don't consider the disfigurement of our countryside with masts a 'disadvantage').

In the words of John Armitt, Network Rail's Chief Executive, in a letter to Dr Caroline Jackson, an MEP for the south-west: "The two basic altemative technologies capable of delivering GSM-R standard communications have considerable drawbacks. First, satellite technology is expensive and does not provide a solution for tunnels, cuttings and highly built-up areas. The second option, leaky feeder cable, is equally if not more expensive and poses real operational issues in terms of the amount of lineside installation required."

A combination of the two technologies could well be the solution. Leaky feeder cable is particularly suited to tunnels and cuttings, and satellite could handle (most of) the rest.

Regarding the problem of using satellite technology in "highly built-up areas": the press release on the Strategic Rail Authority's website (cited earlier) says, in item 7 of the Notes to Editors, "A particular challenge for the UK will be delivering the system in busy commuter and mixed traffic areas, where a technical review of the workings of the GSM-R mobile communications network has highlighted a lack of capacity and resilience as a major technical risk. Currently nowhere in Europe is anyone understood to be planning to implement ERTMS in this type of rail environment, which is common in the UK."

A recent report on the weaknesses of GSM-R in such environments can be found in an article called Rail comms system could delay trains.

Another, and much cheaper, solution would be for Network Rail to make use of the existing mobile phone network for cab-to-signaller voice communications, with a much smaller number of additional masts to fill in gaps in the existing coverage, and satellite technology for ERTMS-related data communications. As mentioned previously, the Cullen Report was quite favourable towards the use of standard mobile phones by drivers and conductors.

Providing uninterrupted coverage to rail passengers is something of a Holy Grail for mobile phone operators (click here for an article on the subject). One or more operators would almost certainly be willing to provide Network Rail and the rail operators with secure in-cab communications at a heavily subsidised price in return for Network Rail's cooperation.

The Tyne and Wear Metro provides one example - Nexus, the Passenger Transport Executive that operates the service, cooperated with the four main mobile operators to install microcells (small antennae) on the network, giving passengers continuous mobile reception. According to an article on the project, "Nexus said that the technology provides additional safety capabilities, allowing train drivers and station staff to make calls to emergency services and control centres." According to another article, Orange is working "in partnership with the necessary rail authorities" to provide mobile reception in tunnels on the East Coast, West Coast, and Great Western lines.

From another direction, GNER is planning to install Wi-Fi networks on its rolling stock - according to a BBC article, "Satellite dishes on the trains will connect to a variety of networks along the route, including digital TV connections and mobile base stations." Virgin are planning something similar to offset the bad reception caused by the silvered windows of their new Pendolino trains.

ip.access is a Cambridge-based company that specialises in providing GSM and G3 access over IP (the internet protocol) using 'nanocells' - tiny antennae the size of a Smartie packet. IP is satellite-compatible, so a directional dish on top of the train could pick up mobile communications signals and distribute them throughout the train. A version of their system is operational on the Kiev Metro. There's more information here. Similar GSM-over-IP technology has been developed by Sweden's Telia Bright.

The most compelling reasons Network Rail's Head of Communications, GSM-R Project, could adduce for not using third-party masts are that "the GSM-R network will be a key element of our operational safety apparatus and as such, the masts will be dedicated to this use to minimise any operational risk. Particularly in sparsely populated areas mobile coverage is poor and masts tend not be in the right places for our intended purpose." We imagine that most people would trust Vodafone or Orange, or almost anyone else, to manage a communications network better than Network Rail. And erecting new masts to fill in the gaps in coverage would be vastly cheaper and less disruptive than building a whole new network, and could be implemented far more quickly. Unfortunately, it seems that Network Rail is institutionally averse to cooperation - see Whatever happened to DART?

And communications technology is advancing all the time. GSM-R, which is based on GSM technology developed in the 1980s and standardised in 1991, is already obsolescent, overtaken by G3, and G3 in turn is threatened by several alternative technologies.

Here's a quotation from the Final Report on West Coast Route Modernisation to the Office of the Rail Regulator, published in June 2000:

The GSM system is being superseded by the third generation mobile telephone system (UMTS [G3]). Although one telecoms operator has stated that it will not guarantee GSM beyond 2009, it is likely that GSM-R will not become technologically obsolescent for about 15 years, by which time the systems would in any case be life-expired.

West Coast Route Modernisation, Report to Office of the Rail Regulator, Booz Allen & Hamilton, June 2000, Section 3.58 (949 kilobyte PDF)

15 years from the date of publication takes us up to 2015 - which is/ the earliest date that ERTMS can be implemented (see above right).

The committee of the UIC International Union of Railways that developed the GSM-R standard is well aware that GSM-R is in its twilight years. Here is a rather tetchy and defensive quote from the FAQ page on their GSM-R website:

Of course, there might be better solutions in theory today if we were starting again. But we're not. GSM-R is today's mobile communications system for the railways. The objective was to find a solution that meets the railways' overall requirements (economically and technically). GSM-R is this solution.... In any case, if we were to start from scratch now we would embrace other possible solutions in the study [our emphasis] - software radio for instance or UMTS [G3].

Bearing in mind that GSM-R is only required by ERTMS Level 2, that the UK is the first (and so far the only) EU country to commit to implementing ERTMS Level 2 on all its track, and that the UK timetable for implementation has been constantly deferred, by the time GSM-R is brought into operation the technology it's based on will be 20 years old or more. "Starting from scratch now" sounds like an excellent idea (though it may still be slightly premature!).

Another promising technology is stratospheric broadband using High Altitude Platforms (unmanned airships or solar-powered gliders flying at an altitude of around 20 kilometres - well above normal aircraft but substantially below orbiting satellites), which has much higher capacity than satellite but doesn't require the masts needed by terrestrial networks, and is cheaper than either. One application the developers consider ideal for this technology is high-bandwidth communication with moving trains using directional antennae.

There's more about the Capanina project (which is EU-funded) here.

Microwave emissions

There is very widespread and serious public concern over the adverse health effects of long-term exposure to low-intensity microwaves. These are implicated in a variety of ailments, including leukaemia and brain tumours.

Network Rail, supported by Government experts, insist that the emissions pose no threat to anybody. However, public confidence in Government experts is not what it was. After all, we were told not long ago that there was no risk from using mobile phones. Now we are told we should use them sparingly, and children should not use them at all.

The Government has recently adopted the guidelines issued by ICNIRP (International Commission on Non-Ionizing Radiation Protection), which are somewhat more stringent than the earlier UK standard. However, in the ICNIRP Guidelines it is stated on the third page that:

"...these guidelines are based on short-term, immediate health effects such as stimulation of peripheral nerves and muscles, shocks and burns caused by touching conducting objects, and elevated tissue temperatures resulting from absorption of energy during exposure to EMF. In the case of potential long-term effects of exposure, such as an increased risk of cancer, ICNIRP concluded that available data are insufficient to provide a basis for setting exposure restrictions...."

Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic, and Electromagnetic Fields (a 612 kilobyte PDF)

In other words, the guidelines are not applicable to circumstances where people are exposed to emissions twenty-four hours a day, every day of the year, for years on end. The guidleines are also rather old (published 1998), and a great deal of research has taken place since.

In any case, there are legal precedents supporting the view that "Genuine public fear and concern is a material planning consideration" that needs to be taken into account by planners (regardless of the views of the authorities and the scientific establishment), and supporting the conclusion of the Stewart Report (May 2000) that a "precautionary approach" should be taken.

This is not such a strange principle: the public's concern about rail safety, compared with the safety of other forms of transport, clearly is not rational, but politicians, bureaucrats, and even the judiciary treat it with the greatest respect.

Click here for a good briefing paper on the legal and health aspects of radio masts.

There is particular concern in the case of children, who are known to be more vulnerable than adults.

A guideline that is often quoted, and is observed by many planning authorities, is that no mobile phone mast should be within 500 metres of a dwelling. But planning authorities have no say with Network Rail's masts.

An excellent article on the health risks of mobile phone masts, written from an initially sceptical point-of-view, was published in an article in The Guardian on April 10 2004. More information on the subject can be found in this section of the Mast Sanity Website.

A good summary of the data specifically related to GSM-R masts can be downloaded from here (In Microsoft Word format).

Are you on NR's hit-list?

Network Rail have picked out sites for most, if not all, of the 2,022 planned masts. Of these, only 188 had been erected by March 2004, according to a a Department for Transport spokesman. One protest group in Wiltshire obtained a list of 183 proposed locations in Network Rail's south-west region (16 others have not yet been identified) - click here for the list, and details of how to get a similar list for your area.

Contents

More trackside masts (1)

NIMBYism is not enough!

Almost everyone in this country will suffer to some extent from Network Rail's GSM-R masts, even if it's "only" by having a favourite view spoilt.

Network Rail justify the masts using two proven propaganda techniques:

Neither of these claims is true.

Network Rail's main weapons are stealth and fear: residents don't get to hear of their plans until the last minute, then panic and try to "pass the parcel" on to some other community.

This "divide and rule" strategy will only work if there is no co-ordinated campaign against the whole project.

The evidence we've uncovered shows that much of Network Rail's rationale is deeply flawed.

If the public at large get to hear about what's afoot, and make their concerns known to the powers-that-be, the chances are that the whole project will be replaced by something more sensible, cheaper, and less intrusive.

See below for how you can help.

ERTMS - the biggest public-sector computer project ever?

ERTMS (the European Rail Traffic Management System) is an ambitious scheme for a Europe-wide computer-controlled rail management system comprising two principal components: ATP (Automatic Train Protection, which, like TPWS, prevents trains from passing signals set at danger) and ETCS (European Train Control System, which automates the flow of rail traffic). Data commmunication via GSM-R-based radio is required for some versions of ERTMS. Click here for a brief description of the various types.

Three main reasons for implementing ERTMS are given: safety, interoperability, and capacity/performance. Let's look at these in turn:

Safety - as both Railway Safety and the Strategic Rail Authority concede, the additional margin of safety provided by ERTMS is trivial and not worth the vast expenditure.

Interoperability - interoperability in the original sense does not apply to the UK, since the only UK lines and trains that might cross borders are exempt from ERTMS. Interoperability in the new sense, of common standards and multi-source procurement, may be of benefit once standards have been fixed - but Network Rail is wilfully throwing away that advantage by pioneering an advanced version of ERTMS that no other country has attempted.

Capacity/performance - The option chosen by Network Rail "is estimated to potentially increase capacity by up to 10% with complementary investment." A possible capacity increase of up to 10% with complementary investment ( that is, one assumes, with extra unspecified expenditure) seems a very dubious return for such a massive high-risk venture.

Could there possibly be a fourth reason - to save money by making drivers and signallers redundant? At some time in the future, it could even be possible that all UK rail traffic would be controlled from a data centre in Bangalore!

Can we afford ERTMS?

An article in the June 2004 issue of Modern Railways called ERTMS: can it be made cost-effective? bluntly states: "Quite simply, as it stands ERTMS is unaffordable."

The latest estimate of the cost of ERTMS, which is contained in the National ERTMS Project Team [NEP] 2003/2004 Progress Report (a 675 kilobyte PDF) is £4,280 million (up from £3,600 million in April 2002). This covers just three lines (the East and West Coast Main Lines and the Great Western route to Bristol/Cardiff) and the trains that run on them. We have found no estimate for the cost of extending this to the entire 16,000-kilometre UK network, which Network Rail now wishes to do.

The £4,280 million budget also excludes "the capital cost of signalling renewals, consequential costs and ETML". According to a technical report prepared by the NEL Consortium for the Health and Safety Executive in 2003, "The cost of the resignalling with CBI [Computer Based Interlocking] is estimated to cost £50 billion over the ERTMS implementation period. The level of this cost compared to the ERTMS capital cost [then about £3 billion] may cause concern and delays, but is thought to be unlikely to stop the project." That's more than 90% of the total projected cost - and its omission from the master plan is nonetheless dismissed as inconsequential!

Reading the 2003/2004 Progress Report is a surreal experience, since virtually all the figures given are positive - that is, Network Rail is representing ERTMS as a profit-making venture. To quote again from the article in Modern Railways:

...present costs and values at discount rates at this stage of development are smoke and mirrors stuff. And for connoisseurs of this sort of thing can I commend the business case for the EDS (ERTMS Demonstration System). This has, we are told, a positive Net Present Value of between £44 million and £48 million over six years on a reported project cost of £60 million.

How can such a trial scheme on a bit of railway more than adequately signalled by Radio Electronic Token Block (RETB) have a business case? Well NEP has put a value on the reduction of risk to the ERTMS implementation programme. Perhaps I should see if the Open University offers a degree in financial sophistry so I can explain this sort of thing more convincingly.

Network Rail are betting huge amounts of public money on unproven technology, in return for virtually no safety benefit and minimal, and entirely speculative, performance gains. In fact, the likelihood is that ERTMS will reduce capacity, just as TPWS has reduced it, according to Train Protection - Review of economic aspects of the work of the ERTMS Programme Team(a 1.5 megabyte PDF), published in 2003 by the Health and Safety Executive.

ERTMS, which has been described by the Strategic Rail Authority as "probably...the largest safety-critical control system project ever undertaken in the UK", is a far more complex project than TPWS. TPWS cost £525 million, exceeding its original budget by £360 million - a 218% overspend (Rail safety: the effectiveness of TPWS for overspeed mitigation, a Health and Safety Executive Paper by HSE Rail, 2003.

The West Coast Main Line (WCML) modernisation programme, which also depended on unproven signalling technology, will over-run its original budget by 650%. If the cost of ERTMS Level 2 overruns to the same extent, it will rise to £32,500 billion (plus the £50 billion for re-signalling, of course, as well as the unbudgeted cost of "consequential costs" and ETML [European Rail Traffic Management Layer]).

It could be even worse: the Health and Safety Executive Paper cited [http://www.hse.gov.uk/research/rrpdf/rr066.pdf] commented that "A further matter of considerable concern is the large increases in the cost of automatic train protection equipment, as is illustrated in Table 2." Table 2 showed that the costs of fitting different components of ATP to the Great Western and Chiltern regions in the five years between 1997 and April 2002 went up, in real terms, by between 324% and 386%.

Perversely, Network Rail are counting on costs going down rather than up. Here's a final quote from the article in Modern Railways:

...the Strategic Rail Authority's Executive Director - Technical, David Waboso, who heads the NEP, is clear that 'the business case for ERTMS is about much lower costs'. By 'much lower' he means half present figures.

This is a pretty heroic aspiration, given that ERTMS costs are uniformly high across Europe. NEP believes that one way of reducing costs would be to open the market to more suppliers.

Since the whole of the European signalling industry is involved in the ERTMS programme, and we have a British chapter in the form of RIASIG (Alcatel SEL, Alstom, Bombardier, Invensys Rail Ansaldo and Siemens), presumably NEP is hoping that the Azerbaijani Signalling Apparat will be able to knock up some reverse engineered safety-critical kit at a third of the cost. Dream on.

Delays? So what!

The implementation schedule for ERTMS has been postponed several times because of budgetary constraints. A two-year deferment of the completion date, from 2008 to 2010, was announced in October 2003 (Cutbacks delay railway system), and a further three-year delay followed in April 2004 (Will rail project ever reach its destination?). Both articles are liberally salted with the usual shroud-waving lamentations about the danger to railway passengers resulting from these delays.

A paper by HSE Rail published in May 2003 states that "ERTMS Level 2 suitable for the UK railway remains a long way off, implementation now projected no earlier than 2015 on highspeed lines. Major uncertainties remain on technical issues and securing funding for development as well as implementation."

Given such long delays, most organizations would reconsider the specification of the project as a whole - particularly as GSM-R is based on obsolescent second-generation mobile technology. However, Network Rail clearly isn't bothered by delays.

According to an e-mail sent by Madelene Klaasen-Bos, Head of Communications GSM-R, on 2 February 2004, mast installation will be completed in the Strathclyde region in August 2004, and also along 190 km of track north and south of Peterborough during late spring/summer of 2004.

One mast campaigner phoned Ms Klaasen-Bos on 8 April, after hearing the news of the latest delays on BBC Radio 4. "She confirmed that their funding had been cut and that this meant that the project would take longer," he reported. "However, in all other respects, nothing has changed - they still want 100-foot masts over the whole network as soon as they can get them."

So Network Rail are continuing to blight the countryside with huge masts - even though they can't be used for many years to come.

WCML modernisation: a grim portent for ERTMS?

The West Coast Main Line (WCML) modernisation programme instituted by Railtrack in 1995 hinged on implementing an experimental high-tech Train Control System known as moving-block, a technology that had never been used on any mainline railway system. The estimated cost was £1.5 billion. In 1999 Railtrack abandoned it, and reverted to conventional signalling. The new estimate for WCML modernisation was then £5.8 billion. In 2002 the Strategic Rail Authority estimated that the final cost when it's completed in 2008 will be £9.8 billion.

ERTMS Level 2 is another high-tech signalling system that is not in use on any mainline railway system. Will that too be aborted in four years' time? And what will be the final cost?

The full story of the WCML fiasco can be read in a two-part Guardian article: Part 1 and Part 2.

Of the GSM-R 188 masts Network Rail had erected by March this year, 176 were installed on the West Coast Main Line. Which is odd, because the version of ERTMS Network Rail plans to install on the WCML (north of Crewe, at least) is Level 1, which does not require GSM-R!

The Uff/Cullen Report - why are Network Rail ignoring it?

Network Rail constantly cite the joint Uff/Cullen Report's call for ERTMS implementation as justification for their plans (a 1.7 megabyte PDF version of the Report can be downloaded from here). But the Uff/Cullen Report called for the implementation of Level 1 ERTMS, not the Level 2 variant that Network Rail have chosen. Both levels incorporate full Automatic Train Protection, but Level 1 is much simpler, can be implemented much more quickly, and (unlike Level 2, which is still half-developed) has already been implemented in several countries.

So why has Network Rail flouted the recommendation of the Uff/Cullen Report?

Could it be because Level 2 requires a radio network and Level 1 does not? It would certainly avoid a lot of awkward questions about Network Rail's failure to modernise their in-cab radio systems over the past decade. Opting for Level 2 ERTMS gives Network Rail a digital network "for free" - the fact that it comes bundled with ERTMS in a package that will cost £4.28 billion, of which less than 5% relates to the radio network, may seem a small price to pay for saving face - particularly since almost all of it will come from the taxpayer. Network Rail's stubborn perseverance in its mast erection programme, despite long delays in the implementation timetable for ERTMS, supports this interpretation.

GSM-R also introduces major technical risks to the implementation of ERTMS, according to Railway Safety and the Strategic Rail Authority:

Although ERTMS is similar in concept to ATP systems already in operation, it has a major difference in that Level 2 and above relies on GSM-R telecommunications. This difference remains the major technical risk. European trials carried out to date have not addressed the GSM-R data requirements for ERTMS in a UK operating and regulatory environment. Other risks include the identification of a viable operational and technical transition strategy, delivery of multi-vendor interoperability, reliability, degraded mode operation, and configuration control.

ERTMS: Towards a Better, Safer Rail System, Railway Safety and the Strategic Rail Authority, April 2002 (808-kilobyte PDF)

Network Rail are ignoring another recommendation of the Uff/Cullen Report (Recommendation 12.4, Extension of BR-ATP), which is to retain and extend the BR-ATP Automatic Train Protection system already in use on the Great Western and Midland Zone lines. Instead, Network Rail plans to abandon its huge investment in BR-ATP just as it's become "fully effective", and replace it instead with the totally unproven ERTMS Level 2.

It seems very unlikely that 33-metre (108-foot) masts every 4 to 6 miles are necessary. GSM masts, which share much the same technology, are typically less than half that height, but have vastly greater ranges:

The base stations for [GSM] macrocells have power outputs of tens of watts and communicate with phones up to about 35 kilometres (22 miles) distant.

Planning Policy Guidance 8: Telecommunications, paragraph 21, effective from 22 August 2001 (976-kilobyte PDF).

We can expect trains to use more powerful transmitters and more sensitive receivers than mobile phones, further increasing the range.

So, in theory, GSM-R masts could be half the height and still be placed 70 kilometres (43 miles) apart - which would mean that only a few hundred would be required to cover the 16,000 kilometres of track in the UK.

Smaller GSM-R masts are available - one manufacturer (MTA) builds 5, 10, and 15 metre masts. The only reason for using higher masts is that (if there are obstacles in the line of sight, eg bridges or buildings) you need fewer of them - but Network Rail wants it both ways.

When asked why, Network Rail simply beg the question, as in this exchange on the Radio Four's You and Yours programme broadcast on 13 May 2004 (see below):

Mark Holdstock, BBC: "So why do these masts have to be so tall, and why do there have to be so many of them?"

Iain Coucher, NR Deputy Chief Executive: "If we had smaller masts we'd obviously have to have a lot more."

Mr Coucher is paid £400,000 a year, so can't be stupid - presumably he chose to misunderstand the question because he didn't want to give a straight answer.

In fact, the straight answer is that the proposed GSM-R network requires closer/taller masts because of the data communications demands of the traffic control component of ERTMS Level 2 - which, as we have seen, is not a requirement of the EU Directive on interoperability, and is not being adopted by any EU other country. See left-hand column.

Analogue in-cab radio systems

This summary of the Network Rail's analogue radio systems dates from 1998:

A Railway Group Standard requires all driving cabs to be equipped with an operational radio enabling communication between train drivers, signallers or control centres. Radio technology - the National Radio Network (NRN) and Cab-Secure Radio (CSR) - is already in use on the majority of the network. NRN is a more general two way system of communication which covers 98% of the network. Complete coverage is not reasonably practicable because of reception problem black spots which are mainly in tunnels and cuttings. CSR radio is a more sophisticated two-way dedicated radio between a specific train and the signal box/control centre, which is more appropriate to Driver Only Operated (DOO) trains in south east England. There are no plans to fit CSR on a national basis.

A New Deal for the Railways, page 22, section 79, HMSO, 20 July 1998 (205 kilobyte PDF)

Their analogue in-cab radio systems are getting on, but, when forced to do so, Network Rail always finds a way to keep them going:

During the course of 1998/99, we established that the National Radio Network (NRN) can be maintained as an effective operational radio system until about 2008, which is about 4 years longer than previously envisaged.

The Annual Reconciliation Statement, Report of Progress Against Plans Set Out in the 1998 Network Management Statement, Network Rail, July 1999 (416 kilobyte PDF)

At the same time, they conveniently discovered that NRN did not need replacement, just a bit of patching:

The DART project (Digital Advanced Radio for Trains) has been curtailed. Railtrack now believes that it is not necessary to renew the current National Radio Network installation; it is sufficient to renew only certain components.

Railtrack's Performance in the Control Period 1995-2001, Office of the Rail Regulator, 1999; Appendix 7, section 7.33

And again last year, when a (temporary) budget squeeze forced them to defer the GSM-R roll-out by two years:

Discussions with the Radiocommunications Agency [now part of Ofcom] have allowed the reversion date for existing radio frequencies to be moved back from 2008 to 2010.

Access Charges Review 2003: Final Conclusions, Office of the Rail Regulator, December 2003; 5.107 (a), page 81: (980 kilobyte PDF)

A company called Ultramast, which used to be a 50:50 joint venture between Network Rail and Marconi until it was sold in late 2002 to engineering group Jarvis, claimed on its website that "With access to the telecommunications expertise of Marconi and the unique property portfolios of Railtrack and British Waterways", it aims to "offer phone operating companies the ability to rapidly enhance their network coverage by implementing a quick mast roll-out plan across the country in locations that have not been previously accessible to them."

They claimed that they were not reliant on 'permitted development rights' under Part 17(A) of the GPDO, which implies that they are hoping to use the Part 24 or Part 25 permitted development rights of commercial operators to erect many hundreds, perhaps thousands, of 15-metre GPRS or G3 masts alongside Network Rail's 30-metre GSM-R masts.

The company has now adopted a very low profile - its website's home page is no longer accessible, though you can reach some pages by searching for Ultramast on Google.

Jarvis has now sold the company.

We also came across a page on the website of AMEC, a project management and services company, describing a contract they have with Network Rail called "The Mast Project", which is summarised as follows:

Cellular phone companies are rapidly expanding the number of base station sites needed to support their network infrastructure. Due to a shortage of available green field sites that are likely to be acceptable to local planning authorities, they have been approaching Railtrack with a view to erecting masts on Railtrack land. This mainly involves replacing the existing Railtrack Cab Secure Radio mast with a Cellular mast.

It seems that the CSR antenna are then hung on the new masts alongside the cellular phone antennae. So presumably the GSM-R masts will be in addition to these new masts, rather than replacing Network Rail's existing masts.

An excellent article from the Daily Telegraph on Network Rail's plans and the protests they're generating, with a good scale diagram of a GSM-R mast next to a house.

A BBC article, Railway phone masts, focusing on one mast planned for Bourne End in Buckinghamshire. Includes comments from visitors (unanimously anti-Network Rail).

A good report on the legal aspects of the planning laws and how Network Rail's interpretation of them may be challenged.

The Tarka Action Group fought magnificently against Network Rail's attempt to erect a number of masts along the famous Tarka Line in Devon. Network Rail appeared to have given up, and chosen instead use an alternative technology they always denied was feasible. In addition to their coverage in the Daily Telegraph (see above), an article about the campaign appeared on the BBC website on 22 May 2003. Click here for a summary of how the Tarka Action Group fought their campaign. In June 2004, however, Network Rail revived their original plan, but with somewhat shorter masts - click here for a report.

Churchdown in Gloucestershire is currently under threat - their website contains useful information (some of which we've borrowed for this page).

New Mill in Wiltshire is in an Area of Outstanding Natural Beauty, which hasn't deterred Network Rail. Their website is here. Several residents, and a representative of Mast Sanity, were interviewed for the BBC Radio 4 You and Yours programme broadcast on 13 May 2004. You can listen to a recording of the programme from this link. You will need a (free) program called RealOne Player.

This email address is being protected from spambots. You need JavaScript enabled to view it. about any relevant websites you come across, and we'll list the best ones here.

The list below provides links to documents or websites relating to other proposed mast locations throughout the UK (excluding the ones linked to above). This email address is being protected from spambots. You need JavaScript enabled to view it. if you come across any others (along with the Web address, if possible).

Cadder, Glasgow. With no prior warning, Network Rail start work on a mast at 3:30am on a Sunday morning.

Saltford, near Bath. The residents discovered that they were targeted only as a result of a local television report prompted by a Mast Sanity press release - so much for Network Rail's community relations policy. There's an article on all six masts scheduled for Bath and North-East Somerset District here.

20 masts in and around Exeter - contains quotes from Mast Sanity.

Bishopbriggs and Hillfoot, East Dunbartonshire

York and North Yorkshire

Misterton and Hewish, South Somerset

Wigan (4 masts)

Somerset (4 masts)

Little Marlow, Buckinghamshire

Burnside, Lanarkshire

Cross Keys, Gwent

Oxford, Cowley and Kidlington.

Dore, a suburb of South West Sheffield

Sheffield, "various locations"

Chilterns, Wycombe area

Wychavon, Worcestershire (4 masts)

Kidderminster, Blakedown railway station

Norfolk - four masts at Worstead Station, Antingham Hill, Cromer (Roughton Road), and Sheringham (Station). This is an HTML version cached by Google - the original has gone missing. It contains this interesting statement: "Due to the height proposed it is Railtrack's intention to offer site sharing locations for other telecommunications operators who need a presence in the area or an increase in the capacity of an existing network."

Craven, Yorkshire Dales - 12 masts; Craven District Council is applying for an Article 4 Direction.

Look for others - click here for a Google search for "Network Rail" mast (radio OR microwave) in UK pages updated in the past 3 months - This email address is being protected from spambots. You need JavaScript enabled to view it. if you find any new pages.

You can help us, and everyone else threatened by these masts (including all those who simply enjoy unspoilt countryside), just by telling other people about Network Rail's plans (and maybe telling about them about this website too).

You can help even more by questioning the need for the whole GSM-R network with politicians and the media.

The more fuss we all make about this issue now, the less likely it is that one of these oversize masts will be coming to a railway near you in the next few years!

Ask your local planning department whether Network Rail is proposing to erect any masts in your neighbourhood. Network Rail's Community Relations Manager has said that "several masts are planned in each Local Planning Authority area", so the chances are that - sooner or later - one will be planned close to you.

If you find that one (or more) masts are scheduled for your neighbourhood, write to your local councillor to object - there's a sample letter here .

Ask your MP to take the subject up with Network Rail and the relevant Government departments. You can find out who your MP is, and how to contact him or her, from this web page. Here is a sample letter.

Request one (or more) of your MEPs to ask Network Rail for a list of planned mast locations in your constituency (as was supplied to Dr Caroline Jackson, MEP for the south-west, by John Armitt, Network Rail's Chief Executive). You can find out the names and contact details of all the Members of the European Parliament representing your region from this web page. There's a sample letter here.

If you are a rail traveller, write to your local Rail Passenger Association (you can get the address from this web page) or to the Rail Passengers Council at this address (click here for a sample letter ):

   Rail Passengers Council
   Whittles House
   14 Pentonville Road
   London, N1 9HF

Write a letter to your local newspaper and/or radio station.

If you have a website, please link to this page.

If you know, or find out, any information that might be useful to our campaign (including relevant websites), please This email address is being protected from spambots. You need JavaScript enabled to view it. If it looks helpful, we'll put it up on this website.