Availability of accessible rail replacement coaches

Temple Meads · 9 Oct 2019

AngusH said:
Out of curiosity, does anyone know whether the service operators, National Express, Mega bus and Citylink, or their partners might have any spare coaches to cover RRB work?

Not many - you may find a few former front line NX vehicles that have been cascaded into their contractors' main fleets, but other than that there isn't much spare capacity with the express operations.

Nat Ex don't like coaches in their livery being used on other work anyway - it could lead to termination of the contract, and it's hard to see NX agreeing to operators helping out their main competition.

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richw · 9 Oct 2019

Will watch with interest how this pans out as there is definitely not the supply to meet demand for the big blockages.

Deafdoggie · 9 Oct 2019

kingqueen said:
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. )

Indeed. Locally school buses here now no longer carry fare-paying pupils to get round this. There has been much protesting, but the rules go against the many alas. There were, of course, no pupils in a wheelchair wanting to get on, but now none of them can get on. It’s widely expected something will happen to a pupil whilst walking to/from school and panic will ensue and common sense may then apply. But in the meantime the coach can’t lethally be provided.

Bletchleyite · 9 Oct 2019

Deafdoggie said:
Indeed. Locally school buses here now no longer carry fare-paying pupils to get round this. There has been much protesting, but the rules go against the many alas. There were, of course, no pupils in a wheelchair wanting to get on, but now none of them can get on. It’s widely expected something will happen to a pupil whilst walking to/from school and panic will ensue and common sense may then apply. But in the meantime the coach can’t lethally be provided.

Of course the only reason they did carry fare-payers was so they could claim BSOG and fatten their pockets...

Deafdoggie · 9 Oct 2019

Bletchleyite said:
Of course the only reason they did carry fare-payers was so they could claim BSOG and fatten their pockets...

the route mainly affected carried around 13 pass holders and around 40 fare-payers

Cesarcollie · 9 Oct 2019

Bletchleyite said:
Of course the only reason they did carry fare-payers was so they could claim BSOG and fatten their pockets...

Possibly, but in a lot of cases the value of BSOG for two journeys a day, 190 days a year, is far outweighed by the hassle and cost of claiming and external audit, the notice periods for registration, and the cost of ticket machines etc....

Bletchleyite · 9 Oct 2019

Cesarcollie said:
Possibly, but in a lot of cases the value of BSOG for two journeys a day, 190 days a year, is far outweighed by the hassle and cost of claiming and external audit, the notice periods for registration, and the cost of ticket machines etc....

You'd think, but pretty much all school bus services in my locality are registered local bus services advertised in local publicity, despite them being pretty much useless to anyone who isn't either a schoolkid or a member of staff at the school.

You'd also think it wasn't worth registering sections of National Express coach routes, but they do. And the likes of the Luton-MK 99 and Oxford-Cambridge X5 - interestingly, the just-off-the-motorway stops they added to the former probably just so it could be registered have turned out to be the busiest at certain times, the MK end being among a large set of warehouses where there are jobs, the Luton end acting as an unofficial "kiss and ride".

RT4038 · 9 Oct 2019

Bletchleyite said:
Of course the only reason they did carry fare-payers was so they could claim BSOG and fatten their pockets...

Your usual acerbic comment rather shows a lack of grasp of the economics ....... school buses are generally tendered (nowadays often by a reverse on line auction) and any advantage that an operator may get in claiming BSOG will inevitably result in a lower tender price, so the value of BSOG will merely pass from the Dft through the bus company to the local tendering authority.

Man of Kent · 9 Oct 2019

RT4038 said:
Your usual acerbic comment rather shows a lack of grasp of the economics ....... school buses are generally tendered (nowadays often by a reverse on line auction) and any advantage that an operator may get in claiming BSOG will inevitably result in a lower tender price, so the value of BSOG will merely pass from the Dft through the bus company to the local tendering authority.

BSOG is not available to operators on tendered contracts (unless it is de minimis). BSOG for such operations is paid directly to the tendering authority, except that the DfT has not varied the amount it pays since its first assessment. So local authorities such as Southend and Luton which I believe subsidise no services at all still receive a BSOG payment from DfT. DfT meanwhile has been clamping down on the eligibility of school services for BSOG, with more and more conditions having to be met in order to receive BSOG.

kingqueen · 9 Oct 2019

Deafdoggie said:
Indeed. Locally school buses here now no longer carry fare-paying pupils to get round this.

Similarly here, and in other areas, from what I understand.

There were, of course, no pupils in a wheelchair wanting to get on,

I wonder how many would have got on were it not for the specialist segregated door- to- door transport provided to SEN pupils by councils. Perhaps many wheelchair users would be able to travel with their non- disabled peers on school buses. Perhaps not. I don't know.

There were no school buses where I was when I was at school. We all caught public buses.

kingqueen · 9 Oct 2019

Bletchleyite said:
Of course the only reason they did carry fare-payers was so they could claim BSOG and fatten their pockets...

The public authority I've been in contact with, has reported that bus operators aren't informed if the public authority has sold permits for spare capacity or not.

Deafdoggie · 10 Oct 2019

kingqueen said:
Similarly here, and in other areas, from what I understand.
I wonder how many would have got on were it not for the specialist segregated door- to- door transport provided to SEN pupils by councils. Perhaps many wheelchair users would be able to travel with their non- disabled peers on school buses. Perhaps not. I don't know.

There were no school buses where I was when I was at school. We all caught public buses.

They only get a specialist bus if they have a ‘statement of special educational needs’ (SEN) being in a wheelchair alone isn’t enough for a SEN. Indeed these days very little is enough for a SEN, but therein lies a whole different story! Most LEAs will do reasonable adjustments, But stop short of issuing a SEN. My son does have a SEN, but it’s a fight every year to get it carried on.

kingqueen · 10 Oct 2019

Deafdoggie said:
They only get a specialist bus if they have a ‘statement of special educational needs’ (SEN) being in a wheelchair alone isn’t enough for a SEN. Indeed these days very little is enough for a SEN, but therein lies a whole different story! Most LEAs will do reasonable adjustments, But stop short of issuing a SEN. My son does have a SEN, but it’s a fight every year to get it carried on.

Yes, very aware of the massive struggle to get statemented and the significant fighting that parents of disabled kids have to do. I have immense respect for such parents and their huge struggle. Also feel a lot for those disabled kids whose parents can't or don't fight...

Given what you've said, I wonder what wheelchair using non-statemented kids do for school transport. No SEN transport, no wheelchair access to standard school buses, are they left reliant on their parents for transport?

lincman · 10 Oct 2019

kingqueen said:
Yes, very aware of the massive struggle to get statemented and the significant fighting that parents of disabled kids have to do. I have immense respect for such parents and their huge struggle. Also feel a lot for those disabled kids whose parents can't or don't fight...

Given what you've said, I wonder what wheelchair using non-statemented kids do for school transport. No SEN transport, no wheelchair access to standard school buses, are they left reliant on their parents for transport?

The law requires that provision is made for all eligible children to be provided with free transport from the age of 5 to 16, children who have physical disability are treated no differently, and where no suitable public transport exists taxis are generally provided. Some authorities do make financial recompense to parents for using there own vehicles.

Deafdoggie · 10 Oct 2019

kingqueen said:
Yes, very aware of the massive struggle to get statemented and the significant fighting that parents of disabled kids have to do. I have immense respect for such parents and their huge struggle. Also feel a lot for those disabled kids whose parents can't or don't fight...

Given what you've said, I wonder what wheelchair using non-statemented kids do for school transport. No SEN transport, no wheelchair access to standard school buses, are they left reliant on their parents for transport?

Generally, if it’s known there will be a wheelchair user, the council cough up for a wheelchair coach to be used. They often don’t mind knowing someone will use it. What they don’t like is paying for every coach to be wheelchair friendly, knowing full well no one in a wheelchair will be using it. Of course, if just using regular service buses they are low floor anyway. There’s only a small number who live close enough to the school so don’t qualify for transport and are unable to make that distance themselves. In that situation though I suspect there’s enough issues to get a statement.

richw · 10 Oct 2019

Deafdoggie said:
Generally, if it’s known there will be a wheelchair user, the council cough up for a wheelchair coach to be used. They often don’t mind knowing someone will use it. What they don’t like is paying for every coach to be wheelchair friendly, knowing full well no one in a wheelchair will be using it. Of course, if just using regular service buses they are low floor anyway. There’s only a small number who live close enough to the school so don’t qualify for transport and are unable to make that distance themselves. In that situation though I suspect there’s enough issues to get a statement.

presumably the local authority know who every possible user of closed school coaches will be so know the passengers they are booking for anyway

philthetube · 12 Oct 2019

Fawkes Cat said:
One solution is using accessible buses rather than non-accessible coaches. This should be doable on a Sunday but more difficult during the rest of the week when the buses are likely to be working scheduled services.

Really don't fancy that on the Sleeper.

cainebj said:
It is actually relevant. Any coach built from 1st January 2001 being used on scheduled service has had to comply with schedule 3 (destination boards, grab rails, floor slope angles, step heights), and any coach built from 1st January 2005 has had to comply with schedules 1 and 3 (full wheelchair accessibility). 1st January 2020 is just the date for all coaches to comply with schedules 1 and 3 to be used on scheduled service.

Source: DVSA MovingOn blog

Unfortunately coaches required for scheduled services are normally being used on them and not available for other work such as RRB

Arctic Troll said:
If coach companies are actively removing wheelchair lifts because it costs them money to maintain, then that is an industry problem. Blaming disabled people for it seems a bit rich.

Thats business, if a company has to charge more for their coaches because of the additional expense or being able to carry wheelchairs then customers will go to others, the company providing the service will go under and therefore back to square one.

So availability will have to increase.

Availability will only increase when prices make it worthwhile of legislation forces it, and if legislation forces up prices that can also impact availability.

Robertj21a · 12 Oct 2019

richw said:
presumably the local authority know who every possible user of closed school coaches will be so know the passengers they are booking for anyway

I don't think Academies go via the local authority.

richw · 12 Oct 2019

Robertj21a said:
I don't think Academies go via the local authority.

I think you’re correct. A local private school charges parents for school transport, I noted they’ve gone fully PSVAR this term with their transport providers.

kingqueen · 27 Dec 2019

Teflon Lettuce said:
are you being deliberately antagonistic? are you dogmatically going to shout down anyone who doesn't agree with your prejudged view of the situation? I and others have told you that, for various reasons PSVAR does not and will not for the foreseable future cover Rail Replacement.

18 months later, in the ORR's "Consultation on Accessible Travel Policy Guidance - accessibility of rail replacement services",

we consider it is clear that where rail replacement services provided by train operators are used the law requires that those services be compliant with PSVAR.

It is doubtless childish and unhelpful to say "I told you so", but I guess I'm doing so anyway - particularly given the repeated and vehement way in which people attempted to dissuade me from my analysis and position. PSVAR does apply to rail replacement services, as I said all along.

richw · 27 Dec 2019

You were right. Fair point.
We will inevitably see one of three things a lot;
1) a downgrade of quality with life expired service vehicles which meet criteria, old darts/ Tridents etc,
2) older coaches under the 20 day annual exemption for vehicles over 20 years old
3) no vehicles available and subsequently no alternative transport for passengers.

JN114 · 27 Dec 2019

kingqueen said:
18 months later, in the ORR's "Consultation on Accessible Travel Policy Guidance - accessibility of rail replacement services",

nowhere in the linked page allegedly said:

we consider it is clear that where rail replacement services provided by train operators are used the law requires that those services be compliant with PSVA

Click to expand...

It is doubtless childish and unhelpful to say "I told you so", but I guess I'm doing so anyway - particularly given the repeated and vehement way in which people attempted to dissuade me from my analysis and position. PSVAR does apply to rail replacement services, as I said all along.

While I do not dispute the veracity of your claims in this thread as a whole, can you please point directly to where your quote comes from. It's not on the linked page, and context of quotes is important; especially where interpretations of legislation are concerned. The press release concerns the start of a consultation into proposed changes to regulations to be imposed by the regulator - the materiel effect of which was to mandate the application of PSVAR regs to rail replacement vehicles. That is manifestly different context in which to take the above quote; and would infer that PSVAR regs do not currently apply to rail replacement vehicles.

kingqueen · 27 Dec 2019

JN114 said:
While I do not dispute the veracity of your claims in this thread as a whole, can you please point directly to where your quote comes from. It's not on the linked page, and context of quotes is important; especially where interpretations of legislation are concerned

Sure. It's in the consultation document (PDF file) page 36 paragraph 3.15.
The context makes it clear that the ORR is clear that the PSVAR apply to rail replacement services. The consultation isn't about whether or not PSVAR applies, or should apply. It's about what the ORR should put in their Accessible Travel Policy guidance as a result.

kingqueen · 27 Dec 2019

richw said:
You were right. Fair point.
We will inevitably see one of three things a lot;
1) a downgrade of quality with life expired service vehicles which meet criteria, old darts/ Tridents etc,
2) older coaches under the 20 day annual exemption for vehicles over 20 years old
3) no vehicles available and subsequently no alternative transport for passengers.

Thank you.
What's happened so far is that the Department for Transport has offered rail replacement operators a month's "special authorisation" (exemption) from the regulations. I wonder if these may be extended or replaced in some way.
There has also been a significant increase in demand from coach operators for accessible vehicles, which I personally consider a good thing.
I don't deny that the three things you state may well be an outcome, but it does appear that the government is aware of this possibility and is currently taking action accordingly.

richw · 27 Dec 2019

A lot of ‘abandoned’ ex national express Caetanos are suddenly being recommissioned and sold on having been sat in fields for several years. Presumably these come fairly cheap for a wheelchair coach

Deafdoggie · 27 Dec 2019

richw said:
A lot of ‘abandoned’ ex national express Caetanos are suddenly being recommissioned and sold on having been sat in fields for several years. Presumably these come fairly cheap for a wheelchair coach

Most will have the wheelchair provision removed. It’s an unnecessary expense for coach operators who don’t need it. RRB isn’t ‘bread and butter’ work for coach operators. They aren’t interested in spending more money on it. TOCs are not interested in paying more for wheelchair coaches. The coach industry is widely expected to largely pull-out of RRB work from the New Year, if all coaches are required to be wheelchair accessible. However, it’s expected the government may change the legislation as it’s unlikely the government will want to be blamed for their being no public transport available during engineering work. Coach companies are already being quite clear that wheelchair coaches can’t be provided at the current price and in the quantities required. It’s a problem of the governments making, so they’ll need to find the solution. It’s possible they will throw some money at it, but more likely the law will be quietly changed.

richw · 27 Dec 2019

Deafdoggie said:
Most will have the wheelchair provision removed. It’s an unnecessary expense for coach operators who don’t need it. RRB isn’t ‘bread and butter’ work for coach operators. They aren’t interested in spending more money on it. TOCs are not interested in paying more for wheelchair coaches. The coach industry is widely expected to largely pull-out of RRB work from the New Year, if all coaches are required to be wheelchair accessible. However, it’s expected the government may change the legislation as it’s unlikely the government will want to be blamed for their being no public transport available during engineering work. Coach companies are already being quite clear that wheelchair coaches can’t be provided at the current price and in the quantities required. It’s a problem of the governments making, so they’ll need to find the solution. It’s possible they will throw some money at it, but more likely the law will be quietly changed.

it’s had a knock on effect on schools contracts. My local authority have made school buses closed doors and no longer allow the kids who live slightly too close to buy passes. Loads of parents gone to media moaning that their little darlings have to walk to school 2.9999999 miles now instead of being able to buy a bus pass.

for those unaware if a school bus takes kids who have to pay for their passes PSVAR applies, school buses only carrying those entitle to free passes it doesn’t. The government have now announced a relaxation until 2022 if less than 20% of passes are paid for. This has annoyed those coach companies who’d became compliant and spent large sums on compliant buses As unfair against the non compliance who now have a 2 year grace period

Robertj21a · 27 Dec 2019

richw said:
A lot of ‘abandoned’ ex national express Caetanos are suddenly being recommissioned and sold on having been sat in fields for several years. Presumably these come fairly cheap for a wheelchair coach

I'm not sure there's a *lot* of those Caetanos 'sat in fields for several years'. Can you clarify ?

Robertj21a · 27 Dec 2019

Deafdoggie said:
Most will have the wheelchair provision removed. It’s an unnecessary expense for coach operators who don’t need it. RRB isn’t ‘bread and butter’ work for coach operators. They aren’t interested in spending more money on it. TOCs are not interested in paying more for wheelchair coaches. The coach industry is widely expected to largely pull-out of RRB work from the New Year, if all coaches are required to be wheelchair accessible. However, it’s expected the government may change the legislation as it’s unlikely the government will want to be blamed for their being no public transport available during engineering work. Coach companies are already being quite clear that wheelchair coaches can’t be provided at the current price and in the quantities required. It’s a problem of the governments making, so they’ll need to find the solution. It’s possible they will throw some money at it, but more likely the law will be quietly changed.

Is it really a problem of the government's making, when the law dates from 2005 ? - I know it has only recently become clearer that RR work is included, but isn't that mainly a failure on the part of coach operators and TOCs ?

Deafdoggie · 27 Dec 2019

Robertj21a said:
Is it really a problem of the government's making, when the law dates from 2005 ? - I know it has only recently become clearer that RR work is included, but isn't that mainly a failure on the part of coach operators and TOCs ?

Coach companies use RRB as an ‘extra’ when coaches that don’t need to be accessible are sat around empty. They have no need to do anything about it, and really don’t mind not doing RRB. The government have been fully aware of this.

Availability of accessible rail replacement coaches

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