None of the existing TOCs existed in 2000, and for all those that used to exist the issue is irrelevant.
To argue a pedantic point - Virgin Trains is the same legal entity, holding the same franchise, as in 2000. Although they're very much an exception.
Quite. I have negotiated many contracts over the years and the assumption was always that both parties had to be aware of and follow the law. But this was a general concern, such as paying taxes and insurance contributions and working hours and employee safety and so on.
Yes, I'd forgotten that the West Coast franchise went that far back! However this franchise is to be handed to a new operator in December this year, before the starting date of the PSVAR regulations. Why should, therefore, Virgin Trains West Coast spend time and effort in trying to solve an issue which can never affect it?
My understanding from reading the law is that this exemption applies when picking up from multiple spots in one local area, and when dropping off at multiple spots in another local area. So long as this is subsidiary to the main point of the trip, which is to take people from one local area to another.
The regulations started many years ago and are in place now. All buses, and all coaches built or first used after 2004, are already covered (bar the 20yo / 20 day exemption.)
So what's your problem?
In what respect?
.
It appears that you consider that it is unlikely that vehicles meeting the PSVAR will be available to do rail replacement services either at all or in sufficient numbers or that the TOCs will not specify their use. But if as you write, all buses and coaches built or first used after 2004, some 15 years ago, are already compliant, then allowing for a 10 to 15 year active life then most currently available vehicles will meet the requirements of the regulations and these will be the vehicles supplied.
That's not what I said. I said that all buses, and all coaches built or first used after 2004, are already covered (bar the 20yo / 20 day exemption.)
Maybe wheelchair passengers aren't doing 21 day tours of Europe because the vehicles aren't accessible?
Coach operators and manufacturers disagree. Non-wheelchair coaches still produced more than wheelchair ones. If it were to apply, then I think day trips, etc will be a thing of the past. However many coach operators without a wheelchair coach in their fleet are offering day trips and hires after the 1st January, so the industry either doesn’t believe that the rules apply, or are happy to blatantly ignore it. But were it to apply, the costs would outweigh the returns, and so the demise of the coach trip.
Coaches built or first used after 2004 are not exempt from the wheelchair obligation.
I think this is easily the simplest and best summary of the issue so far.
I agree (with the limited exception that any school bus that carries any child whose right to travel on that bus has been paid for separately e.g. by the local authority selling permits for spare seats, does need a wheelchair lift. )
