The Anonymous Widower

Birmingham Airport Mulls Plan For Terminal Inside HS2 Station

This is the title of an article in Construction News.

This Google Map shows Birmingham Airport, the current Birmingham International station, the NEC, with the M42 Motorway going North-South down the Eastern side.

Currently, it is planned that the Birmingham Interchange station for HS2, would be on the other side of the M42 to the NEC.

Surely, the Construction News headline is indicating that something better can be done.

In an ideal world, Birmingham Airport would have one station for HS2, West Coast Main Line and local train and tram services, with a step-free lift/escalator connection between all platforms and both Departures and Arrivals at the Airport.

 

May 19, 2017 Posted by | Travel | , , , , | Leave a comment

Tram 18, Where Are You?

This article in Rail echnology Magazine is entitled Midland Metro tram shipped to Spain for battery fit-out ahead of OLE-free operation.

It describe how Tram 18 is on its way to Zaragoza to be fitted with lithium-ion batteries, so that the UK’s first battery tram can start running in 2019, after the track is laid to Victoria Square in Birmingham and the railway station in Wolverhampton.

February 15, 2017 Posted by | Travel | , , , | Leave a comment

Exploring The Route Of The Midland Metro Extension To Victoria Square

The extensions at both ends of the Midland Metro in Birmingham and Wolverhampton City Centres will be a first for the UK, in that they will be catenary-free and the trams will run on battery power.

This Google Map shows the area, where the initial extension will go in Birmingham City Centre.

birminghammetroextension

Places of interest are.

  • The cathedral is in the North-East corner.
  • New Street station is in the South-East corner.
  • Victoria Square and the Town Hall are just to the East of the middle.
  • Centenary Square is towards the West side.

This description comes from this page on the Metro Alliance web site.

840m of twin track from Birmingham Grand Central at Stephenson Street, up Pinfold Street through Victoria Square, Paradise St, past Paradise Circus into Centenary Square at Broad St.There will be an intermediate stop outside the Town Hall in Victoria Square, and we will interface with the Navigation Street link.

One of the problems at the moment, is that the development of Paradise Birmingham, seems to sit in the middle of the route.

These pictures show the area of Victoria Square and the route up from New Street station.

Note.

  • The steep hill of Pinfold Street.
  • The route seemed to have been prepared ready for the track to be fitted into the road surface.
  • Utilities seemed to have been moved.
  • When I took the pictures, the Midland Metro had parked a tram at the limit of the current track at the bottom of Pinfold Street.

Climbing The Hill

You can’t accuse Birmingham of lacking ambition, as Pinfold Street is a proper hill.

But then!

  • It is the only steep hill on the route to Centenary Square.
  • The tram will start the ascent with full batteries.
  • There will be no problems coming down.
  • This extension is only 840 metres in length.
  • The MetroCentro in Seville has used similar technology on a 1.4 km. route since 2007.
  • CAF have technology that charges batteries fast.
  • Battery technology has moved on in the last ten years.

If in practice, it does prove a difficult climb, overhead wires could be put on sufficient of the lower part of the up-track on Pinfold Street.

These wires wouldn’t be visible from Victoria Square, so wouldn’t effect the architectural integrity pf the area.

Onward to Edgbaston

According to this article in Rail Technology Magazine, the further four kilometre extension to Egbaston, is also intended to be catenary-free.

As the trams could be charged at Edgbaston, I think this could be possible.

But I doubt CAF would propose the use of batteries, if they hadn’t already proven the range, which is not outrageous.

The Next Step

I looked at a lot of the route of the first section to Victoria Square today, and it would appear that the roadway has been prepared for fitting the track.

So could we see an accelerated development of the first part of the extension?

It would be a good test of the technology, with little risk to the Midland Metrolink!

If the trams can’t make the hill on baqtteries, it would need to be wired, but you could always blame Spanish engineering.

Conclusion

It is a very well-designed scheme.

I wonder, if we’ll see Edinburgh batteries on their CAF trams?

 

 

 

January 25, 2017 Posted by | Travel | , , , , | Leave a comment

The Cost Of Tram Batteries

This article in Rail Technology Magazine is entitled Midland Metro tram shipped to Spain for battery fit-out ahead of OLE-free operation.

One Midland Metro tram has been sent back to the factory in Zaragoza to be fitted with two roof-mounted lithium-ion cells and after testing it will be returned to the West Midlands in the Autumn, where more testing will be performed, prior to starting running on the catenary-free streets of Birmingham and Wolverhampton.

After a successful completion of testing on the first tram, the other twenty trams will be converted.

This is said in the article about costs.

The total cost to the WMCA of fitting out the fleet will be £15.5m, but the authority says that it will save £9.24m on infrastructure costs on the first four extensions to the Metro network alone, with further infrastructure savings planned as future extensions take place.

So the savings can go a long way to help pay for the trams to run on the four extensions.

The cost of the modifications to each tram is £738,000, but if the infrastructure savings are factored in, the modifications cost just £298,000 per tram.

I also wonder if the layout of the Midland Metro, with a fairly long wired central section and a catenary-free section at either end is ideal for battery operation, as the trams will have a long section to fully charge the batteries.

But it looks like trams will reach Victoria Square and Wolverhampton station in 2019, Edgbaston in 2021 and the Eastside extension to Curzon Street will be completed in 2023.

Perhaps, the most interesting section in the article is this paragraph.

The WMCA is also evaluating a proposed Wednesbury to Brierley Hill extension to identify the viability of catenary-free sections.

Could this mean that the South Staffordshire Line, which will be used for the extension will be without catenary? As the tram does small detours into Dudley and at the Merry Hill Shopping Centre, then these sections could be wired to charge the batteries, leaving the South Staffordshire Line without any wires. I estimate that the distance the tram would travel would be about seven miles each way.

As Network Rail want to run both trams and freight trains on the South Staffordshire Line, this might allow both to share an unelectrified line, if they have the right wheel and track profiles.

There certainly seems to be some very innovative ideas around, when it comes to using trains and trams in City Centres.

 

 

January 23, 2017 Posted by | Travel | , , , , | Leave a comment

Out Of The Mouths Of Brummies

The December 2016 Edition of Modern Railways has a special report on railways and trams in the West Midlands.

There are some choice quotes from those involved in planning the future of the rail network in the area.

On HS2

“It’ll be half an hour from Birmingham Interchange station to the Crossrail interchange at Old Oak Common. That means Birmingham Airport will be in London Zone 4, timewise.”

On Stations

“Nobody looks at their strategic value to the community”

On New Street Station

“The Birmingham New Street Gateway rebuilding has quadrupled the passenger circulation area in the station, but it hasn’t addressed the key issue of lack of track capacity”`

On Battery Power For Trams

“Since then there has been lots of work and we’re now comfortable that battery technology has advanced sufficiently for it to be viable.”

“Under test conditions with plain straight track a tram could travel 20 km catenary-free. In practice, this would be rather less for a fully laden tram ascending the 9% gradient on Penfold Street. The longest catenary-free run we’ve envisaged is around 2 km, and we’re comfortable we can achieve that”

On More Trams

“They will have to be bespoke to a degree in order to operate catenary-free, but the rail sector is embracing alternative technology and on-board energy store so we may be looking at something more advanced afain.”

Conclusion

It’s all upbeat and it looks like Birmingham is looking forward to the battery trams.

No-one mentioned the B-word!

 

November 24, 2016 Posted by | Travel | , , , | 1 Comment

The New Bromsgrove Station

This is the new Bromsgrove station, which opened this week.

It is not what you’d call a spectacular station, but it certainly fulfils the objectives of the design.

  • Act as a second Southern terminus for three trains per hour on Birmingham’s Cross-City Line.
  • Be able to accept trains up to nine cars on the Cross-Country route from Gloucester, Worcester and Hereford through Birmingham and onto the East Midlands and Yorkshire.
  • Provide a step-free interchange, between trains, buses, cars and cycles.
  • Provide a Park-and-Ride station for Birmingham.

But as it has four platforms, will soon be electrified and have connections across the City, will it after the timetable has settled, become an important interchange that takes the pressure from Birmingham New Street? I think it will, as Reading does for Paddington, Stratford does for Liverpool Street and Clapham Junction, does for ictoria and Waterloo, in London.

It is also not finished and needs a shop and coffee stalls. In some ways it has a similar aura to the new Lea Bridge station in East London. Both stations shout that they are open for business, so please send us some trains and we’ll make the passengers happy.

It could turn out to be a masterstroke.

The electric trains on the line that will work the electrified service are Class 323 trains. There are forty-three, three-car units of which London Midland have twenty-six units, or just thirteen six-car trains, which is the train-length, the line obviously needs.

Will they get the other seventeen units from Northern, as that company gets new rolling stock, to create a fleet that could serve the line adequately?

They could also be looking at new trains. Something like four-car Class 710 trains, which are being built for similar urban routes on the London Overground, would be ideal. And in these Brexit times, they are built in Derby.

If Class 710 trains were to be used, they open up the intriguing possibility of fitting some or all of them with on-board energy storage.

This would enable the following routes.

  • Bromsgrove to Worcester is only a dozen miles, and doesn’t include the notorious Lickey Incline, which will soon be electrified. So it would be possible to run a frequent Birmingham to Worcester service using onboard energy, which would also serve Droitwich Spa and the new Worcestershire Parkway station.
  • The Camp Hill Line provides an alternative route across Birmingham City Centre. It is not electrified, but as it is short, it would be well within onboard energy storage range.
  • On the other side of Birmingham, it is only about twenty-five miles or so from the electrified Cross-City Line to the electrified West Coast Main Line at Nuneaton.

So could we see a second Cross-City Line in Birmingham from Worcester to Nuneaton via Bromsgrove, Camp Hill, Water Orton and Coleshill Parkway?

It would need no new electrification and just appropriate track and station improvements.

 

July 14, 2016 Posted by | Travel | , , , , | Leave a comment

After The Northern Hub, Is Network Rail Planning A Midland Rail Hub?

The study on Network Rail’s web site is entitled West Midlands and Chilterns Route Study, proposes a concept of a Midland Rail Hub.

By adding the following infrastructure.

  • Bordesley Chords and new platforms at Moor Street
  • More tracks through Water Orton
  • Kings Norton upgrade
  • Snow Hill Platform 4
  • Begin rollout of Digital Railway

Network Rail feel, it will bring the following benefits.

  • Up to 10 extra trains every hour
  • More freight trains
  • New journey opportunities between East and West Midlands
  • Unlocking new jobs
  • Maximising benefits of HS2.

It doesn’t appear to be as radical as the Northern Hub.

These are my notes and thoughts on the various proposals.

Bordesley Chords

This Google Map shows the Bordesley area of Birmingham.

Bordesley Chords

Bordesley Chords

In the top-right or north-eastern corner of the map is Birmingham City Football Ground.

In the middle of the map is Bordesley Circus, which is a roundabout, that is one of the most dangerous for pedestrians in the country. When I was last there, it was being improved and I wrote  My Least Favourite Roundabout Gets Pedestrian Lights. I hope they’re working on Tuesday, 13th December, when I’ll be going to see Ipswich play.

Bordesley station, which is one of the worst stations in the UK, lies to the South-West of this roundabout and is on the Chiltern Main Line into Birmingham Moor Street station, although services don’t stop.

Running almost North-South across the map is the Camp Hill Line, which incidentally passes behind the stands at the football ground.

Where it crosses the Chiltern Main Line, there is a chord allowing limited connection between North and East.

I would assume that as the report says Bordesley Chords, that there will be some extra connectivity between these two lines.

Under the future of the Camp Hill Line on Wikipedia, this is said.

The reinstatement of local rail services to the former Camp Hill Line has been a long term aspiration of the City, and during 2007, Birmingham City Council announced that they were looking into the possibility of reopening the line between Kings Norton and Birmingham Moor Street via the construction of a railway viaduct from Sparkbrook to Bordesley, where trains would be taken into the “old” Birmingham Moor Street station. In October 2007, a 1500-name petition was handed in to the council asking for the line to be re-opened. In 2013 the proposal was shelved indefinitely.

As Kings Norton is to the South, this would need a West to South connection at Bordesley.

These pictures show the area from a Chiltern Train going into Moor Street.

Salubrious it is not! There is certainly a lot of space on the North side, but there might be less on the South. This Google Map shows the area between the station and where the two lines cross.

Bordesley Station And Chords

Bordesley Station And Chords

Note the double-track chord between the Camp Hill Line to the North and the Chiltern Main Line to the East. This chord gives services from the Chiltern Main Line to access Birmingham New Street station. If you take a train from Oxford to Birmingham New Street, it will take this chord, if it doesn’t go via Coventry.

From what I have seen in Manchester and some parts of London, the area could surely be put to a better purpose, perhaps driven by a rebuilt Bordesley station, with regular services to Moor Street, Kings Noton and Solihull. The area does have the added factor of water in the shape of one of Birmingham’s numerous canals.

Hopefully, the first piece of development in a very run-down area, the sorting of a decent walking route between Bordesley station and Birmingham City Football Ground has been completed.

New Platforms At Birmingham Moor Street Station

This Google Map shows Birmingham Moor Street station.

Birmingham Moor Street Station

Birmingham Moor Street Station

The most northerly pair of platforms in the station are numbered 1 and 2 and are for the through lines to Birmingham Snow Hill station.

Over the last few years, work has opened the next pair of bay platforms 3 and 4. On my last trip to Birmingham in June, I arrived in Platform 4.

A Chiltern Main Line Train In Platform 4 At Birmingham Moor Street Station

A Chiltern Main Line Train In Platform 4 At Birmingham Moor Street Station

Platform 5 on the other side of Platform 4 may have been reinstated, but there doesn’t seem to be any trains using it, as yet!

The map shows that there would appear to be space to open Platforms 3, 4 and 5, but could a clever architect squeeze in a Platform 6?

These pictures show the space for a possible Platform 5 and 6.

There would certainly appear to be space to shoe-horn two tracks and a new Platform 6 between the current Platform 5 and the retaining wall.

As the pictures show, Platform 5 is a platform that is long enough for any train currently envisaged that might call at Moor Street station.

Looking at the map of the station, it might even be possible to make Platform 6 even longer, if this were thought to be needed.

More Tracks Through Water Orton

This Google Map shows Water Orton station and the lines through it.

Lines Through Water Orton Station

Lines Through Water Orton Station

If you look up services from Water Orton and Coleshill Parkway stations, they are certainly of the turn-up-and-wait-forever variety.

Water Orton has one train every two hours to Birmingham, but at least Coleshill Parkway has a train every half-hour.

Perhaps more lines through Water Orton will enable more trains through the area.

Looking at the rail map of Birmingham, it would be possible to go from Water Orton via the Camp Hill Line to Kings Norton and if the North to West chord was built at Bordesley to Moor Street.

It would certainly be the view of many, including myself, that a Parkway station needs a train or tram every fifteen minutes.

Kings Norton Upgrade

If the Camp Hill Line is reopened to passenger trains, then Kings North station will be the terminus.

This Google Map shows the station.

Kings Norton Station

Kings Norton Station

It is a large station with an unused island platform in the middle.

These pictures show Kings Norton station.

There is certainly work to be done.

But the station also has a lot of potential and space that can be utilised. It might even be possible to fit in a bay platform to turn trains back to Moor Street and New Street.

Birmingham Snow Hill Platform 4

Wikipedia says this about platforms at Birmingham Snow Hill station,

The present Snow Hill station has three platforms for National Rail trains. When it was originally reopened in 1987 it had four, but one was later converted in 1999 for use as a terminus by Midland Metro trams. The original tram terminus closed in November 2015, in order for the extension of the Midland Metro through Birmingham city centre to be connected. This includes a dedicated embankment for trams alongside the station, and will also include a new through stop serving Snow Hill. This will eventually allow the fourth platform to be returned to main-line use.

As the Midland Metro now has its own new platform outside the station, the fourth platform can soon be converted back to heavy rail use.

These pictures show the current state of the closed tram platform.

I don’t think that converting it back to heavy rail will be the most difficult of jobs.

Birmingham Station Connectivity

Although, not on the Network Rail infrastructure list, I feel that to gain the full benefits of HS2, then the line must be properly connected to Moor Street and New Street stations.

I can easily walk between Moor Street and New Street stations, but I do feel that Birmingham’s solution of using the Midland Metro as a link and to the Curzon Street HS2 station, is not the way to do it.

It needs some form of people mover. Perhaps a travelator would be better.

City Centre Ticketing

In Liverpool, a ticket to Liverpool stations, allows you to use the Underground to any of the other stations in the City Centre.

In London, many visitors by rail, add a Travelcard to their rail ticket.

Perhaps, in Birmingham, a ticket to Birmingham stations, should include the Midland Metro in the City Centre? Or a simple add-on for the Metro between Jewellery Quarter and Five Ways could be added for a few pounds.

At present, you have to buy a separate ticket. How visitor-friendly is that? At least a short journey is only a pound

If Birmingham is to make the most out of the opportunity of HS2, then they must use easy and understandable ticketing.

Chiltern’s Superb Trains

My trip down to Birmingham was in a Class 168 train, which although was a good experience for a diesel multiple unit, was spoilt as one engine went AWOL and we were late in to Moor Street.

But going home to London, I rode in what I think are one of the best long distance trains anywhere in Europe; Chiltern’s rakes of Mark 3 coaches pulled and pushed by a modern Class 68 locomotive.

  • Nearly every seat gets a table and a window aligned to it.
  • The seats are spcious and comfortable.
  • The ride is the superb one, you always get from a Mark 3 coach.
  • Trolley-service of drinks and a buffet on most services.
  • Free wi-fi.
  • London to Birmingham return for £19.20 with a Railcard.
  • I’ve never travelled on Chiltern’s Mark 3 coaches and been unable to read my paper flat in front of me on the table.

The experience may be slower than Virgin’s, but give me Standard Class on Chiltern against First on Virgin every time between London and Birmingham.

The only problem, is that Marylebone station, isn’t as accessible as Euston from where I live. However, when Crossrail opens, times will be within a few minutes.

I can’t help feeling that Transpennine’s decision to use Class 68 locomotives and rakes of new CAF Mark 5 coaches across the Pennines, was influenced by the success of Chiltern’s flagship service and its superb rolling stock.

I’m looking forward to riding the CAF coaches in a few years, to see how they stand up to an almost forty year old British Rail coach.

I wonder how many Spanish engineers have ridden Chiltern’s trains?

I also feel that the Class 68 locomotive is an asset to a passenger service, in that so many diesel locomotives look dirty and smelly, but Class 68s seemed to have been designed to keep clean and also look how a locomotive should; powerful, purposeful and sleek.

For those, who don’t like that the trains are still diesel-hauled, there is even a Spanish solution for that, if the lines ever get electrified, in the shape of the new Class 88 electro-diesel locomotive, which is a sister of the Class 68 locomotive.

And of course, if Chiltern need some more trains and can’t find the Mark 3 coaches, they can always buy some new coaches from CAF.

 

Conclusions

It’s a very sensible plan and it will open up all sorts of possibilities for Birmingham.

The chords at Bordesley and the extra tracks through Water Orton would seem to open up a new route for trains across the city from Moor Street band Kings Norton to Water Orton and Nuneaton.

  • New subsurban services could link Nuneaton and Kings Norton to Moor Street.
  • Cross-country services might use Moor Street with a reverse, rather than New Street.
  • Extra services from Moor Street to Nuneaton might take pressure off the heavily-loaded New Street to Birmingham route.
  • How would the new station at Kenilworth station fit in?

But there are railways all over this area and I’m sure that the Bordesley and Water Orton improvements, will not be the last.

Already there is talk of reopening, the Sutton Park Line and the Stonebridge Railway.

I asked about Kenilworth station. I don’t know, but after Bordesley and Water vOrton are upgraded, there would be the possibility of a Warwickshire Circle, starting and finishing at Moor Street.

 

  • Moor Street
  • Solihull
  • Warwick Parkway
  • Warwick
  • Leamington Spa with a reverse.
  • Kenilworth
  • Coventry
  • Coventry Arena
  • Bedworth
  • Bermuda Park
  • Nuneaton
  • Coleshill Parkway
  • Water Orton
  • Moor Street

It would be a route, where several stations could be reopened or built from scratch. Leamington Spar incidentally already has a bay platform for the reverse.

I also think, that one of the biggest beneficiaries of all this will be Chiltern Railways.

Consider.

  • Their two Birmingham termini of Show Hill and Moor Street are getting extra capacity.
  • Moor Street will become a big terminal with two through and four bay platforms, all of which will be able to handle the longest Chiltern trains.
  • Birmingham New Street station lacks capacity.
  • The Birmingham New Street to Coventry route is seriously crowded.
  • In Will Chiltern Railways Get A Second London Terminal At Old Oak Common?, I talked about Network Rail’s ideas to link the Chiltern route to the new station.
  • Banbury station has been upgraded for more traffic.
  • Chiltern will be running to Oxford station by the end of this year.
  • Chiltern have plans in hand to run to Milton Keynes station.

We’ll certainly see extra services from London to Birmingham and possibly beyond, but will we see a triangular route going between London – Oxford – Birmingham – London?

It will depend on whether the passengers want it, but from Chiltern’s point of view, it might mean that their platforms in London, Oxford and Birmingham, and their trains, saw higher utilisation.

I suspect too, that the Oxford -Birmingham leg has more paths available and that Chiltern’s capacity problems are mainly at the London end of the Chiltern Main Line, especially now, that Banbury has been remodelled.

Chiltern Railways are an ambitious company and if they get a second terminal in London at Old Oak Common, they will certainly use it profitably.

I think that the Network Rail report shows that a few simple improvements, when thought through and executed with care can produce improvements not suspected in the original plans.

But all rail planning has to discount the London Overground Syndrome, where new stations, routes and trains, attract more passengers than originally expected.

 

July 8, 2016 Posted by | Travel | , , , , , , , | Leave a comment

Mainland Birmingham

Just listening to Adrian Chiles doing a live broadcast on the Brexit debate from the Bull Ring in Birmingham.

He has just interviewed a third-generation Indian sub-continent stall-holder, who described himself on-air as born in Mainland Birmingham.

Even Adrian, who is a Brummie, was caught out by the phrase.

The wonders of the English language.

May 17, 2016 Posted by | World | , , , | Leave a comment

Is The West Midlands Going To See A Boom In Rail Station Building?

Yesterday, when I wrote West Midlands To Get A New Freight Interchange, I wondered, if the original Four Ashes station would be rebuilt.

On looking at the list of proposed stations on Wikipedia, I noticed the first was Brinsford Parkway station, which I’d never heard of before.

But it turned out it was just a couple of miles South of Four Ashes. Wikipedia says this about Brinsford Parkway station.

It would be located on the Rugby-Birmingham-Stafford Line loop of the West Coast Main Line, and would give the north of Wolverhampton local commuter trains easing congestion on the A449, M6 and M54 motorways. Penkridge is the only station that still remains open on the line between Wolverhampton and Stafford.

The proposed station would serve a new development on the MoD depot at Brinsford (whose builder would fund the station), other local communities and passengers drawn from the motorway network. It would provide Park and Ride facilities, with a large car park.

It sounds like Wulfrunians are thinking holistically!

It looks like a good idea to me, as it ticks a lot of boxes.

So, I then went through Wikipedia’s lists of current and proposed station projects, to see what other interesting ones were in the pipeline. I found these in the West Midlands.

The West Midlands has certainly expanded its suburban services with electrification, new trains and the Midland Metro in the last couple of decades and it looks like they will be building more train and tram lines in the future.

Birmingham To Peterborough Line

In my view the most interesting proposal is the two new stations on the Birmingham to Peterborough Line. Except for Water Orton, this line is station free between Coleshill Parkway and Birmingham New Street.

If Fort Parkway and Castle Bromwich stations were to open, surely two trains per hour on this line will not be enough, so I do wonder if there are plans to add extra services to and from somewhere like Nuneaton with its connections up and down the West Coast Main Line and possibly extend them the other way to perhaps the new Bromsgrove station to the West of Birmingham.

It strikes me that there will be some reorganisation. I suspect though, that one of the problems is that it would appear that the line from Nuneaton to Birmingham is not electrified, although Nuneaton and Birmingham New Street stations are. There is also incomplete electrification between Birmingham New Street and Bromsgrove stations.

It looks to me like a cash of call in some Aventra IPEMUs. The only problem might be hauling a full load of passengers up the Lickey Incline on the on-board energy storage.

April 15, 2016 Posted by | Travel | , , | Leave a comment

My Least Favourite Roundabout Gets Pedestrian Lights

When you go to Birmingham City to watch a match from Bordesley station, you take your life in your hands to cross the road. I reported the bad roundabout in A Pedestrian Crossing From Hell.

But look what’s happening!

My Least Favourite Roundabout Gets Pedestrian Lights

My Least Favourite Roundabout Gets Pedestrian Lights

Hopefully, the lights will be working before someone gets killed.

January 23, 2016 Posted by | Sport, Travel | , | 1 Comment