What are TOCs doing post accessible RRB advice?

kingqueen · 26 Dec 2019

Bletchleyite said:
Even though this means the end of the RRB, i.e. there will simply be no service at all for engineering periods, as there are not enough accessible vehicles around to ensure all vehicles are accessible?

The difficulty is, it's the law: it is currently a criminal offence for anybody to operate an inaccessible rail replacement vehicle (with a couple of temporary exceptions). That's now been formally recognised by the ORR and the DFT. The fact that the rail and bus industry hasn't realised this until now, and that the DVSA have quite clearly failed in their duty to proactively and reactively enforce this obligation over the past 15 years, means the industry and government are how in this classical dilemma: a situation nobody wants to be in, nobody chose and which has no acceptable options / conclusions. A real cleft stick. And yes, I should imagine that the public sector Equality duty would definitely come into play in any Governmental decision to introduce legislative change to reduce or remove accessibility obligations regarding rail replacement vehicles.

Regarding taxis, you must be very tall to have that issue

I am indeed very tall. I'm 6'7" / 2.00m tall. But I have multiple wheelchair-using friends who aren't so ludicrously tall, who have the same problem.

- are there vehicles that are suitable, e.g. minibus type taxis with a lift of the type used for community transport services?

They're much better. Some are better than others. They aren't as ubiquitous as may be thought though. They can be surprisingly difficult to source and book, particularly around school travel times. [/QUOTE]

Bertie the bus said:
Could you clarify that point please. There are 600 or 1200 accessible coaches in existence which is the absolute maximum that could theoretically be made available for rail replacement services or there are 600 or 1200 that are available for rail replacement services?

Sure. The following is from the Office of Rail and Road's consultation document.

Looking across the UK and not only at its members, CPT estimated that circa 2,200 accessible coaches have been built for the UK market, of which around 1,000 are still regularly used on express and other scheduled services. Of the remaining 1,200, its understanding is that around 600 might still be fully accessible though the ability to accommodate all types of wheelchairs and scooters varies, whilst the remaining 600 vehicles have had their lifts removed to increase coach capacity (in some cases from 49 seats to 70 seats) and to reduce maintenance costs. CPT commented that the availability for rail replacement work of those coaches that are compliant will depend on geographic location and use on other services that may or may not require PSVAR compliance.

PhilStockley said:
No they haven't - at least not in respect of coaches. PSVAR only applies to coaches used on *any* scheduled service from 1st January 2020,

That's not the case. Check out, for example, this Government webpage: https://www.gov.uk/government/publi...ervice-vehicle-accessibility-regulations-2000

Vehicles covered
The Public Service Vehicle Accessibility Regulations (PSVAR) applies to all new public service vehicles (buses or coaches):

introduced since 31 December 2000

with a capacity exceeding 22 passengers

used to provide a local or scheduled service

these vehicles have been being used in perfectly good faith, not because of some wanton desire by criminal bus operators to get round the law).

I agree, operators have not been knowingly or intentionally breaking the law. They've still been breaking the law, though.

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PhilStockley · 26 Dec 2019

kingqueen said:
That's not the case

I was just preparing an indignant reply saying that it is the case, being full time in the industry and having lived through the whole process and having the dates etched on my brain, but then stopped to think that yes of course you are right in respect of newer coaches. So I apologise for misleading. The truth is somewhere between the two.

Further down the same Government web page...

Timescale
All full size single deck buses over 7.5 tonnes will be fully accessible from 1 January 2016, and all double deck buses from 1 January 2017.

New buses weighing up to 7.5 tonnes and coaches have been required to have wheelchair access from 1 January 2005.

All buses weighing up to 7.5 tonnes have been required to be fully accessible from 1 January 2015 and coaches will be fully accessible from 1 January 2020.

So if a coach used on a rail replacement service was built new on or after 1/1/05, then yes you are right in your assertion. But if a coach was built prior to 31/12/04 (of which there are still many around), then there has been no requirement for this to be accessible - and indeed still isn't for another five days - in any context.

Bertie the bus · 26 Dec 2019

kingqueen said:
Sure. The following is from the Office of Rail and Road's consultation document.

Thanks. So the railway uses on average 1,000 vehicles per week and there are 600 available vehicles which are fully accessible and another 600 which were built to be fully accessible but may not be now. The 1000 average per week is probably skewed somewhat by the amount of engineering work done at Christmas.

That sounds like a bit of a mismatch between demand and availability but not the crisis some are making it out to be. Better planning and potentially diverting more trains around engineering work would reduce the mismatch further.

kingqueen · 26 Dec 2019

PhilStockley said:
So if a coach used on a rail replacement service was built new on or after 1/1/05, then yes you are right in your assertion. But if a coach was built prior to 31/12/04 (of which there are still many around), then there has been no requirement for this to be accessible - and indeed still isn't for another five days - in any context.

Cheers Phil. Yes, I agree.

PhilStockley · 26 Dec 2019

Bertie the bus said:
That sounds like a bit of a mismatch between demand and availability but not the crisis some are making it out to be. Better planning and potentially diverting more trains around engineering work would reduce the mismatch further.

While I can see that's where the numbers might lead you, I don't think it's as simple as that. Speaking anecdotally (as someone who knows quite a lot of coach operators and has also worked on the bus/coach side of rail replacement for many years - planning, managing, driving and supervising) there simply aren't large numbers of accessible coaches that aren't already being used on these services, and as of right now, I know many coach operators who are desperately seeking accessible second hand coaches. So there definitely feels like a massive shortage.

I don't have access to any detail about the numbers quoted, but I strongly suspect the mismatch is because a large number of the accessible coaches that on the face of it appear to be available, are in fact in the hands of coach holiday companies/tour operators, who use them full time on touring commitments and have no desire to be involved with rail replacement.

Deafdoggie · 27 Dec 2019

Bertie the bus said:
Thanks. So the railway uses on average 1,000 vehicles per week and there are 600 available vehicles which are fully accessible and another 600 which were built to be fully accessible but may not be now. The 1000 average per week is probably skewed somewhat by the amount of engineering work done at Christmas.

That sounds like a bit of a mismatch between demand and availability but not the crisis some are making it out to be. Better planning and potentially diverting more trains around engineering work would reduce the mismatch further.

A lot of the accessible coaches are with companies who don’t do RRB work. The majority are also based “down South” so Northern areas find it even harder to get them. But if EVERY RRB is required to have wheelchair access expect RRB to stop. If it’s just a requirement to have one running (say you have four coaches all running on the same route at the same time) some maybe salvageable. However, with an insistence that RRB have wheelchair spaces many coach firms have already said they will no longer provide RRB from the New Year (it’s cheaper than converting coaches or buying new, and no one appears willing to pay more for RRB to fund this) so days of replacement services are limited.
the only possible solution may come from public demand. “No trains into London, and no replacement buses as there are not enough to carry wheelchair passengers, even though their are no wheelchair passengers” isn’t going to make the government look good, so a change in law may come. Trust me, coach and rail companies are already talking to the press about this kind of scenario. They don’t want to carry the blame for this, best to get the press on their side now, and get the government blamed. But, as it stands, there are simply not enough accessible RRB to fulfill requirements from February. There is simply no choice but to change the law, or stop running RRBs. That’s the stark truth.

Robertj21a · 27 Dec 2019

I know it won't dramatically change everything but we do need to remember that there is nothing to stop a *bus* being used on rail replacement work instead of a coach. All buses should now meet PSVAR requirements so it's more a question of suitability. For shorter distances there's no reason why a bus shouldn't be used (outside London, only a few are at present), although routes where there may be a lot of luggage might have a few problems.
On Sundays and Bank Holidays there will be plenty of buses available, so the Easter/Xmas major close downs could be covered, it's likely to be the Saturdays when there won't be sufficient buses.
What is the average length of a rail replacement trip (I don't mean those terribly long distance ones!) ?????

Deafdoggie · 27 Dec 2019

Robertj21a said:
I know it won't dramatically change everything but we do need to remember that there is nothing to stop a *bus* being used on rail replacement work instead of a coach. All buses should now meet PSVAR requirements so it's more a question of suitability. For shorter distances there's no reason why a bus shouldn't be used (outside London, only a few are at present), although routes where there may be a lot of luggage might have a few problems.
On Sundays and Bank Holidays there will be plenty of buses available, so the Easter/Xmas major close downs could be covered, it's likely to be the Saturdays when there won't be sufficient buses.
What is the average length of a rail replacement trip (I don't mean those terribly long distance ones!) ?????

There are very few spare buses. Fleets are worked very intensively.
Maybe Sundays and Bank Holidays will have spare buses. But then you don’t have drivers. Service bus drivers doing a RRB then have to work the more restrictive EU driving hours for the next 13 days. Service bus rotas are not designed for this, So service bus providers generally don’t bother with RRB for this reason. A few have coach drivers, a few have an EU rota. But not enough to make it viable.

Robertj21a · 27 Dec 2019

Deafdoggie said:
There are very few spare buses. Fleets are worked very intensively.
Maybe Sundays and Bank Holidays will have spare buses. But then you don’t have drivers. Service bus drivers doing a RRB then have to work the more restrictive EU driving hours for the next 13 days. Service bus rotas are not designed for this, So service bus providers generally don’t bother with RRB for this reason. A few have coach drivers, a few have an EU rota. But not enough to make it viable.

Yes, I agree that there are very few spare buses - hence my point about Saturdays being a key problem. I guess a lot of these issues come down to just where in the country we are talking about - the make up of local fleets - length of RR etc.

Bletchleyite · 27 Dec 2019

Bertie the bus said:
That sounds like a bit of a mismatch between demand and availability but not the crisis some are making it out to be. Better planning and potentially diverting more trains around engineering work would reduce the mismatch further.

More diversions would be a positive outcome, but you've still got to serve the stations you're diverting away from.

Bletchleyite · 27 Dec 2019

Robertj21a said:
I know it won't dramatically change everything but we do need to remember that there is nothing to stop a *bus* being used on rail replacement work instead of a coach. All buses should now meet PSVAR requirements so it's more a question of suitability. For shorter distances there's no reason why a bus shouldn't be used (outside London, only a few are at present), although routes where there may be a lot of luggage might have a few problems.

Toilets might also be an issue. It continues to rile that those with a frequent need for the toilet are considered somehow less disabled than those in a wheelchair, despite the fact that the lack of public conveniences in 2019 Britain means these people are often effectively housebound. (It is an even larger issue, admittedly, for those in a wheelchair and in that position).

OK, you could schedule a couple of service station stops on the M6 if you were RRBing Crewe to Carlisle, but less easy if you were doing the S&C.

Robertj21a · 27 Dec 2019

Bletchleyite said:
Toilets might also be an issue. It continues to rile that those with a frequent need for the toilet are considered somehow less disabled than those in a wheelchair, despite the fact that the lack of public conveniences in 2019 Britain means these people are often effectively housebound. (It is an even larger issue, admittedly, for those in a wheelchair and in that position).

OK, you could schedule a couple of service station stops on the M6 if you were RRBing Crewe to Carlisle, but less easy if you were doing the S&C.

My feeling is that a good proportion of RR work is much more localised than those ones where toilet or motorway service stations come into the consideration. Longer distance clearly needs coaches, if only for the likely volume of luggage - not the same issue as a RR from, say, Merthyr to Pontypridd.

Bletchleyite · 27 Dec 2019

Robertj21a said:
My feeling is that a good proportion of RR work is much more localised than those ones where toilet or motorway service stations come into the consideration. Longer distance clearly needs coaches, if only for the likely volume of luggage - not the same issue as a RR from, say, Merthyr to Pontypridd.

Indeed. Notably Merseyrail RRBs, which historically were almost always on a Saturday and/or Sunday, used the school bus fleets from the week provided by the local small bus companies of questionable repute, e.g. what we used to as kids call "Cr***y Al's" who I believe are still in business!

The trouble with the school bus fleet, though, is that a lot of that is high floor because other provisions are made for wheelchair users e.g. the minibuses I mentioned upthread. That has meant that the old practice of registering school buses as local routes for BSOG purposes (see the thread on that I created) is dying out, as these can no longer be used for scheduled services, but school and works services I believe class as private hire.

But then you've got work like when the north WCML is closed - it would be good to see more S&C diversions, say, but what do you do for say Lancaster, Oxenholme and Penrith? Running Preston-Carlisle is not a suitable job for a city bus, and this would cause big issues for people with other disabiliities e.g. back problems and toilet urgency. One thing that makes me despair is why wheelchairs seem to be the only form of disability considered. Most disabled people do not use a wheelchair, and while things like lifts help everyone, the use of unsuitable vehicles on long-distance RRB runs do not. (I would agree if you are RRBing Merseyrail a low floor city bus is the best thing to use).

Metal_gee_man · 27 Dec 2019

So when a non-PRM train carriage is attached to a PRM compliant set it makes it compliant correct! i.e A 153 with a PRM 150!
So if a disabled accessable taxi or minibus was paired with a non-PRM coach for each and every run, then TOCs would remain compliant?
Whilst not the cheapest way, that provides the best short term outcome.
Beyond there each TOC should only be allowed one blockade at a time, this would allow for a solitary provider to be set up or a very specific contract drawn up with a transport provider to provide compliant vehicles. This will result an a waste of resources if the compliant vehicles aren't used outside of RRB use for either the TOC or the contractor.
It is funny it does depend on the parent company of the TOC on how well the service is run.
GTR and SE are owned by Go-Ahead and Keolis, when any rail replacement takes place in these areas a large number of Go-Ahead controllers and buses come out of the woodwork. They have a number of instantly GO TO coach and bus operators (primarily TravelMaster) and funnily they've just upgraded a number of their fleet to 100 seat (19 plate) accessable Double deckers.
So some TOCs have pulled their fingers out of their bums.
But for a TOC who doesn't run buses or coaches, this switch could be very challenging.

Bletchleyite · 27 Dec 2019

Metal_gee_man said:
So when a non-PRM train carriage is attached to a PRM compliant set it makes it compliant correct! i.e A 153 with a PRM 150!
So if a disabled accessable taxi or minibus was paired with a non-PRM coach for each and every run, then TOCs would remain compliant?

That is what I think should be the case, but in fact it is not. As the law stands, EVERY vehicle must individually be accessible, if I'm reading the above thread correctly.

It's a well-meaning law, but I suspect RRBs were not thought of when it was introduced - indeed, it's only recently that it has even come to light that they were included in it.

Notably it presumably also causes issues for NatEx and Megabus running duplicates, who could before hire any old coach presuming that the service car was accessible? So either more accessible coaches will be purchased (as NatEx and Megabus duplicates are big business), or those operators will resort to "when it's full it's full"?

Deafdoggie · 27 Dec 2019

Robertj21a said:
Yes, I agree that there are very few spare buses - hence my point about Saturdays being a key problem. I guess a lot of these issues come down to just where in the country we are talking about - the make up of local fleets - length of RR etc.

The problem remains drivers though. Working coach driving hours for two weeks instead of bus hours isn’t practical for most Bus operators.

Bletchleyite · 27 Dec 2019

Deafdoggie said:
The problem remains drivers though. Working coach driving hours for two weeks instead of bus hours isn’t practical for most Bus operators.

I do wonder if post-Brexit EU hours will become required only for work into the EU, with UK work on domestic rules - this would solve that issue. However I doubt it's high on the list of law-change priorities.

Metal_gee_man · 27 Dec 2019

Bletchleyite said:
I do wonder if post-Brexit EU hours will become required only for work into the EU, with UK work on domestic rules - this would solve that issue. However I doubt it's high on the list of law-change priorities.

I understand the idea, but post brexit will coaches stop travelling on a ferry or train to France? So regardless of what professional drivers want the EU law will take full effect when in Europe, I will be shocked if HGV and PCV driving hours ever become nationalised again because of the sheer International nature of their work

Class 170101 · 27 Dec 2019

Bletchleyite said:
I do wonder if post-Brexit EU hours will become required only for work into the EU, with UK work on domestic rules - this would solve that issue. However I doubt it's high on the list of law-change priorities.

Metal_gee_man said:
I understand the idea, but post brexit will coaches stop travelling on a ferry or train to France? So regardless of what professional drivers want the EU law will take full effect when in Europe, I will be shocked if HGV and PCV driving hours ever become nationalised again because of the sheer International nature of their work

Technically could happen if EU changed their rules again and we didn't follow suit.

More fundamentally though how do you solve the problem that certain stations are not accessible and never likely to be so (impractical and prohibitively expensive)?

Robertj21a · 27 Dec 2019

Class 170101 said:
Technically could happen if EU changed their rules again and we didn't follow suit.

More fundamentally though how do you solve the problem that certain stations are not accessible and never likely to be so (impractical and prohibitively expensive)?

Is this also a valid new thread for the Infrastructure part of the forum ?

Class 170101 · 27 Dec 2019

Robertj21a said:
Is this also a valid new thread for the Infrastructure part of the forum ?

Not in my thinking. My line would be more running buses to / from certain stations. They might be great for rail replacement locations but poor for Disabled users. For example LNWR bus to Stanmore (indirectly) for Euston but I would be surprised if you could board at Stanmore, Baker Street or Euston Square (for Euston) without needing assistance.

Robertj21a · 27 Dec 2019

Class 170101 said:
Not in my thinking. My line would be more running buses to / from certain stations. They might be great for rail replacement locations but poor for Disabled users. For example LNWR bus to Stanmore indirectly) for Euston but I would be surprised if you could board at Stanmore, Baker Street or Euston Square (foor Euston) without needing assistance.

My suggestion related to your comment that some stations cannot/never will be suitable for the disabled. I can't believe that will be allowed to continue forever. Surely, the infrastructure thread needs to highlight where work is needed and how it can be achieved ?

Deafdoggie · 27 Dec 2019

Bletchleyite said:
I do wonder if post-Brexit EU hours will become required only for work into the EU, with UK work on domestic rules - this would solve that issue. However I doubt it's high on the list of law-change priorities.

No. Driving hours are now enshrined in UK law, so will not change. Along with driver CPC too. Although both introduced by the EU they are now UK law.

Bletchleyite · 27 Dec 2019

Deafdoggie said:
No. Driving hours are now enshrined in UK law, so will not change. Along with driver CPC too. Although both introduced by the EU they are now UK law.

The law can be changed, of course, just like any other EU law, all of which work that way.

Deafdoggie · 28 Dec 2019

Bletchleyite said:
The law can be changed, of course, just like any other EU law, all of which work that way.

It could be changed. But there are no plans to & it is unlikely to be as drivers doing continental work would need to work EU hours & it just adds an unnecessary level of complication and confusion. It would also be complex for digital tachographs to know if you were doing this all-new UK or EU driving hours

Bletchleyite · 28 Dec 2019

Deafdoggie said:
It could be changed. But there are no plans to & it is unlikely to be as drivers doing continental work would need to work EU hours & it just adds an unnecessary level of complication and confusion. It would also be complex for digital tachographs to know if you were doing this all-new UK or EU driving hours

There are no specific plans to repeal any EU regs, but it will certainly happen over time - a "bonfire of red tape" would be a popular move, it was last time.

Many coach companies don't do international work at all, and it would be far easier for them.

Robertj21a · 28 Dec 2019

Bletchleyite said:
There are no specific plans to repeal any EU regs, but it will certainly happen over time - a "bonfire of red tape" would be a popular move, it was last time.

Many coach companies don't do international work at all, and it would be far easier for them.

I'm sure that *most* UK coach companies do not do international work at all.

Bletchleyite · 28 Dec 2019

Robertj21a said:
I'm sure that *most* UK coach companies do not do international work at all.

Quite possibly so, and I'd imagine those that do probably have a set of drivers that do that sort of work and a set that don't[1], so not that hard to partition it, either.

[1] Spending several days away from home on a frequent basis is not for everyone, and most likely those who do do it like doing it so will be happy doing it often. This happens in other industries too - often those who do business travel do it often, while others don't do it at all.

Deafdoggie · 28 Dec 2019

Bletchleyite said:
Quite possibly so, and I'd imagine those that do probably have a set of drivers that do that sort of work and a set that don't[1], so not that hard to partition it, either.

[1] Spending several days away from home on a frequent basis is not for everyone, and most likely those who do do it like doing it so will be happy doing it often. This happens in other industries too - often those who do business travel do it often, while others don't do it at all.

Bletchleyite said:
There are no specific plans to repeal any EU regs, but it will certainly happen over time - a "bonfire of red tape" would be a popular move, it was last time.

Many coach companies don't do international work at all, and it would be far easier for them.

Robertj21a said:
I'm sure that *most* UK coach companies do not do international work at all.

Many coach companies don’t go over the water. But that doesn’t mean the law doesn’t apply to them. It would only get even more complex if another layer of red tape was introduced with different rules for those driving service buses, those driving UK only coaches & those driving EU coaches.
It isn’t practical to impose service driving hours on UK coach drivers, the argument is that service bus drivers can go longer without breaks as they are doing stop-start driving anyway, whereas coach drivers are often motorway driving which is more monotonous and tiring and needs more breaks. To decide this is now untrue would be a major safety u-turn and I can’t see it being ratified.
So if coach drivers need different regulations to bus drivers, then it makes sense to keep them the same as EU coach drivers. coach drivers from other countries would conform to EU hours when driving over here, so seems a little unfair to say our own drivers can do different hours. Also impossible to police what driving hours a UK driver should be doing. Are they only driving in the UK? Will they be going abroad? Have they been abroad? How would anyone know at a roadside check?

Bletchleyite · 28 Dec 2019

Deafdoggie said:
But that doesn’t mean the law doesn’t apply to them

Why do so many people in here think the law is immutable?

What are TOCs doing post accessible RRB advice?

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