Bantamzen
Established Member
Actually that's a good point: no, I didn't expect it. I expected some form of derrogation extension of one form or another. What would perhaps have been a better way of putting it, is that I was pointing out the blatant disingenuous nature of his original statement. And for that matter, the 3 month extension.What I meant was: I would have hoped and expected all agencies involved to have realised over the past 20 years, that the accessibility regulations apply to rail replacement buses, such that it didn't come as a nasty surprise 19 years later. Then perhaps we wouldn't be needing these ridiculous last-minute bureaucracy-intensive and unsettling extensions, the huge stress to operators and all the rest of it; the industry would have grappled with the issues long ago, and come to some form of solution (and I'm not going to attempt to guess what form that solution would have taken.)
I blame the DVSA as much as anybody. They are tasked with enforcing the PSVAR, given a budget of £100,000 per year to do so, are theoretically the experts in the area, yet have apparently not realised that RRVs are subject to PSVAR and have done nothing to promote or enforce compliance in this situation at all over the past 20 years. Their enforcement manual, issued April 2019, still says that PSVAR is enforceable under the Disability Discrimination Act 1995, which was revoked in 2010 and is so irrelevant.
The problem here is that there has not been a legal requirement for all buses/coaches to be compliant, just those used in public services such as defined in law. So many operators whose business is primarily private / holiday charter have not been required to provide compliant vehicles, and as such this means they do not need to go to the additional expense of making all their vehicles compliant. And why would they? After all for most RRB is a very infrequent side business, not the main priority of their business models and certainly not worth the additional investment in making all vehicles compliant.
And so we are left with a potential chronic shortage of compliant vehicles for RRB work, and two stark choices. Allow exceptions to the regulation to allow RRB operations to continue, with of course strict requirements to arrange alternative compliant transport for those people & any companions needing it. Or strictly enforce the letter of the law and potentially force TOCs to not arrange RRBs, cancelling entire timetables for planned disruption, and leave passengers stranded for hours in the case of unplanned disruption whilst they try to source enough compliant vehicles, regardless of whether they are actually needed or not.