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Availability of accessible rail replacement coaches

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Bantamzen

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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manual, issued April 2019, still says that PSVAR is enforceable under the Disability Discrimination Act 1995, which was revoked in 2010 and is so irrelevant.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.
 
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richw

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Given just how many years the bus and rail industries have known this requirement was coming, it's hard to see what they have to complain about.

why would any operator invest 75000 upwards for a few weekends work a year, unless they needed the psvar vehicle for other uses. Private hire doesn’t require psvar which is the bread and butter for most operators.
 

philthetube

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I can't see what they could have done about it, I can't see how the tocs or coach companies could have made arrangements, it had to be sorted by the government.
 

TUC

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why would any operator invest 75000 upwards for a few weekends work a year, unless they needed the psvar vehicle for other uses. Private hire doesn’t require psvar which is the bread and butter for most operators.
The time for the industry to argue that was long ago, when the requirements were proposed. What you don't do is ignore the requirements for years, and then complain when they are introduced.
 

TUC

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Part of the problem for the industry's reputation in this is that they have shown little interest in promoting accessible alternatives for passengers in wheelchairs even in the current arrangements. Time and again, publicity for RRBs state that it will not be possible to carry passengers in wheelchairs, with no mention of alternative transport being arranged for such passengers. It may well be that a TOC would make such arrangements if they knew a passenger in a wheelchair will be travelling, but the failure to actively make that clear creates the impression that they are seeking to avoid needing to do so. It is that which then feeds into the reaction against TOCs seeking derogations now.
 

Bantamzen

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The time for the industry to argue that was long ago, when the requirements were proposed. What you don't do is ignore the requirements for years, and then complain when they are introduced.

But isn't the industry's problem. Companies that operate only private or holiday charters do not need compliant vehicles. And it is often those same companies that have traditionally supplied RRBs. It is not their fault that this legislation did not take into account this kind of thing, the fault lies fairly & squarely with the legislators.
 

33017

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But isn't the industry's problem. Companies that operate only private or holiday charters do not need compliant vehicles. And it is often those same companies that have traditionally supplied RRBs. It is not their fault that this legislation did not take into account this kind of thing, the fault lies fairly & squarely with the legislators.
Quite. It was only mid-December when the rail industry was told the PSVAR exemption around private hire would no longer apply and all coaches on rail replacement work would have to comply.

I’ve been told there are only 259 PSVAR compliant coaches in the entire country...
 

RT4038

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I’ve been told there are only 259 PSVAR compliant coaches in the entire country...

I don't think that can be right - the combined total of vehicles working National Express/Megabus/Citylink/Stagecoach Express/Green Line etc type routes must be at least 750 (all PSVAR), plus vehicles that had been running these and have gone into the second hand market. Granted many of the latter may have had their lifts removed. Some coach operators have bought some new compliant vehicles as well.
 

Robertj21a

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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.

Agreed. The DVSA must take much of the blame for all this.

I know you've been heavily involved in this issue (and school buses etc) and I think it's fair to say that few other people, even now, would have interpreted PSVAR correctly if it hadn't been for all the concerted effort put in by you. Well done for bringing it to everyone's attention.
 

Robertj21a

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Quite. It was only mid-December when the rail industry was told the PSVAR exemption around private hire would no longer apply and all coaches on rail replacement work would have to comply.

I’ve been told there are only 259 PSVAR compliant coaches in the entire country...

Whatever the figure (it's certainly very low), it rather disguises the fact that there are very many thousands of *buses* that meet the PSVAR legislation, and found in all parts of the country. Are we all getting too hung up on coaches, rather than buses ?

I know that buses aren't always ideal (distance, comfort, luggage space) and that most of these buses will be tied up on existing routine work, but we are talking about pre-planned RR, not emergencies, so there's time to make suitable arrangements.

For shorter distance RR work, particularly if there won't be loads of luggage, I can't see why buses can't be considered - after all, that's what they use for much of the RR work in London.
 

JonathanH

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On the use of buses, isn't the answer here for private hire coach companies to supply the drivers and service bus companies to provide the relevant vehicles?
 

TUC

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Whatever the figure (it's certainly very low), it rather disguises the fact that there are very many thousands of *buses* that meet the PSVAR legislation, and found in all parts of the country. Are we all getting too hung up on coaches, rather than buses ?

I know that buses aren't always ideal (distance, comfort, luggage space) and that most of these buses will be tied up on existing routine work, but we are talking about pre-planned RR, not emergencies, so there's time to make suitable arrangements.

For shorter distance RR work, particularly if there won't be loads of luggage, I can't see why buses can't be considered - after all, that's what they use for much of the RR work in London.
I agree. That's exactly what I was just thinking.
 

Robertj21a

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On the use of buses, isn't the answer here for private hire coach companies to supply the drivers and service bus companies to provide the relevant vehicles?

Why does it need the private hire coach companies to be involved at all ?
 

kingqueen

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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
I agree that this is a significant contributing reason. When the Government introduced the regulations in 2000, they said they intended to address the issue of accessible private charter coaches in subsequent legislation. They have never done so.
Quite. It was only mid-December when the rail industry was told the PSVAR exemption around private hire would no longer apply and all coaches on rail replacement work would have to comply.
The law hasn't changed; it has always been the case that rail replacement vehicles are subject to the PSVAR. The Office of Rail and Road published legal advice specifically stating that the PSVAR apply to rail replacement vehicles, in September 2019.
I’ve been told there are only 259 PSVAR compliant coaches in the entire country...
The Confederation of Passenger Transport, being the largest industry lobby organisation, provided estimates to the Department for Transport that there are or were 2,400 accessible coaches in the country. 1,200 are in use for scheduled services such as National Express / Scottish Citylink / Megabus. 600 have had access features such as wheelchair lifts removed. That leaves 600, which are doubtless in use for other things and thus many will not be available.
I know you've been heavily involved in this issue (and school buses etc) and I think it's fair to say that few other people, even now, would have interpreted PSVAR correctly if it hadn't been for all the concerted effort put in by you. Well done for bringing it to everyone's attention.
Thank you very much.
 

The Planner

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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.
It might actually go a different way, where a TOC will refuse disruptive access on the basis they cannot move people at all, or we get more of the Do Not Travel messages which goes against the Putting Passengers First mantra we have at NR.
 

Bantamzen

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It might actually go a different way, where a TOC will refuse disruptive access on the basis they cannot move people at all, or we get more of the Do Not Travel messages which goes against the Putting Passengers First mantra we have at NR.

I am almost certain that the latter scenario would be the case. Indeed, maybe it has already been the case with the Kings Cross blockade & LNER? Perhaps they have quietly concluded that in order to get regular enough coaches running from Peterborough into central London they would have to book non-compliant vehicles, and being effectively a public sector run company they didn't want to risk not being seen as fully compliant?

Note this is pure speculation on my part, but speculation based on my experiences in the public sector.
 

richw

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The time for the industry to argue that was long ago, when the requirements were proposed. What you don't do is ignore the requirements for years, and then complain when they are introduced.

rail replacement isn’t the bread and butter, it’s merely a small bonus add on that doesn’t pay particularly well.
On the use of buses, isn't the answer here for private hire coach companies to supply the drivers and service bus companies to provide the relevant vehicles?

where are these service buses coming from? Certainly isn’t many sat spare barring Sunday’s
 

Bletchleyite

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I can't see this being resolved by anything other than:-

1. No rail replacement, i.e. if the trains are off, they are off.
2. A change in the law
3. New exemptions being issued every few months

I would expect 3 most likely, then possibly 2.
 

Meerkat

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I can't see this being resolved by anything other than:-

1. No rail replacement, i.e. if the trains are off, they are off.
2. A change in the law
3. New exemptions being issued every few months

I would expect 3 most likely, then possibly 2.

3 isn’t sustainable for long before getting a PR backlash.
How difficult can it be to have PRM taxis on call? As the driver licensing is easier it would be a good gig for a national company to provide them.
 

Llanigraham

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3 isn’t sustainable for long before getting a PR backlash.
How difficult can it be to have PRM taxis on call? As the driver licensing is easier it would be a good gig for a national company to provide them.

Might work in an urban area, but try finding ANY taxis around here, or on the Heart of Wales, or in many rural areas.
 

Robertj21a

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rail replacement isn’t the bread and butter, it’s merely a small bonus add on that doesn’t pay particularly well.


where are these service buses coming from? Certainly isn’t many sat spare barring Sunday’s

I agree, but we are only talking about pre-planned RR. As far as I know, that is often many weeks/months in advance - in most parts of the country it should be possible to pull sufficient resources together, in conjunction with any PSVAR coaches if available. The operators may, of course, suggest that such a provision comes at a cost........
 

Bantamzen

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3 isn’t sustainable for long before getting a PR backlash.
How difficult can it be to have PRM taxis on call? As the driver licensing is easier it would be a good gig for a national company to provide them.

That depends on the number of PRM taxis available in any given area, and how much TOCs would be prepared to have them 'on call'. In general, taxi companies like bus companies like to have their vehicles out & about and earning money. So if you want them on call, it'll cost, a lot.

I agree, but we are only talking about pre-planned RR. As far as I know, that is often many weeks/months in advance - in most parts of the country it should be possible to pull sufficient resources together, in conjunction with any PSVAR coaches if available. The operators may, of course, suggest that such a provision comes at a cost........

That only works if operators don't already have advance work booked, which is how most private coach operators work. They don't sit around on ranks waiting for work at the last minute.
 

Meerkat

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That depends on the number of PRM taxis available in any given area, and how much TOCs would be prepared to have them 'on call'. In general, taxi companies like bus companies like to have their vehicles out & about and earning money. So if you want them on call, it'll cost, a lot.



That only works if operators don't already have advance work booked, which is how most private coach operators work. They don't sit around on ranks waiting for work at the last minute.

Theres bloody loads of the horrible things round here (effectively sitting right at the back of an empty minivan, over the axle).
Can’t be too difficult or expensive in the Uber age. Getting paid for hours snoozing/watching TV without necessarily using any fuel etc. How long does it take to get passengers on a RRB? For non-booked PRM folk you could even have some of the cabs on 15 mins notice so they could still do short private jobs. Got to be cheaper than somehow getting PRM coaches to be available (and probably a better service for the user)
 

Bantamzen

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Theres bloody loads of the horrible things round here (effectively sitting right at the back of an empty minivan, over the axle).
Can’t be too difficult or expensive in the Uber age. Getting paid for hours snoozing/watching TV without necessarily using any fuel etc. How long does it take to get passengers on a RRB? For non-booked PRM folk you could even have some of the cabs on 15 mins notice so they could still do short private jobs. Got to be cheaper than somehow getting PRM coaches to be available (and probably a better service for the user)

Well I can't speak for 'here' wherever that may be. But where I am, Bradford, accessible taxis make up only a tiny fraction of the overall number of taxis. And the same can probably be said about many towns and cities, most taxis in the country are not compliant to the letter of the law. So, and I am just speculating here, but I imagine in this Uber age (although what one taxi company's business model has to do with this I'll never know!) if it were so easy and inexpensive they would all do it. Yet they don't, a lot like private coach companies.

As for having taxi drivers sitting around all day on the hope of a job. Good luck with your business case, because you'll need it!! Oh and a bag load of cash!!
 

33017

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I don't think that can be right - the combined total of vehicles working National Express/Megabus/Citylink/Stagecoach Express/Green Line etc type routes must be at least 750 (all PSVAR), plus vehicles that had been running these and have gone into the second hand market. Granted many of the latter may have had their lifts removed. Some coach operators have bought some new compliant vehicles as well.
Sorry, I should have been clearer. That figure excludes coach companies with regular fare-paying passenger routes such as National Express and Megabus as they do not make their vehicles available for rail replacement work.
 

Bletchleyite

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Sorry, I should have been clearer. That figure excludes coach companies with regular fare-paying passenger routes such as National Express and Megabus as they do not make their vehicles available for rail replacement work.

I've seen branded NatEx coaches on RR work before.

Out of interest, have any regular users of NX and Megabus noticed a removal of duplicate coaches and therefore "when it's full it's full" on those companies? Dupes were normally non-accessible coaches.
 

33017

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Whatever the figure (it's certainly very low), it rather disguises the fact that there are very many thousands of *buses* that meet the PSVAR legislation, and found in all parts of the country. Are we all getting too hung up on coaches, rather than buses ?

For shorter distance RR work, particularly if there won't be loads of luggage, I can't see why buses can't be considered - after all, that's what they use for much of the RR work in London.
Service buses are ok if the distance is relatively short but they are not allowed to be used for more than (I think) 35 miles. This means much rail replacement work is beyond their range.

I know that buses aren't always ideal (distance, comfort, luggage space) and that most of these buses will be tied up on existing routine work, but we are talking about pre-planned RR, not emergencies, so there's time to make suitable arrangements.

The legislation also applies to emergency provision, something that's particularly challenging at the best of times.
 

Robertj21a

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Service buses are ok if the distance is relatively short but they are not allowed to be used for more than (I think) 35 miles. This means much rail replacement work is beyond their range.



The legislation also applies to emergency provision, something that's particularly challenging at the best of times.

There's no 35 mile limit for the buses, quite apart from which much rail replacement work is less anyway. You're probably getting confused with the 50km limit and the domestic hours issues for drivers.

As far as I know there are exceptions for PSVAR vehicles in an emergency situation.
 

Meerkat

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As for having taxi drivers sitting around all day on the hope of a job. Good luck with your business case, because you'll need it!! Oh and a bag load of cash!!
How much does a taxi driver expect to make in a day? Lots of the time they are waiting or returning earning nothing, and when they have a fare what is their marginal profit? In railway cost terms I don’t reckon it’s that much. Ask for bids to snooze in their cab for a day and see what offers you get.
It does depend on the level of provision that would be considered PRM acceptable for unbooked users - if you are allowed to say 15mins notice then drivers could stay at home or take local jobs whilst on call.
 

Bantamzen

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How much does a taxi driver expect to make in a day? Lots of the time they are waiting or returning earning nothing, and when they have a fare what is their marginal profit? In railway cost terms I don’t reckon it’s that much. Ask for bids to snooze in their cab for a day and see what offers you get.
It does depend on the level of provision that would be considered PRM acceptable for unbooked users - if you are allowed to say 15mins notice then drivers could stay at home or take local jobs whilst on call.

Well you could always find out how much it would cost by booking a taxi to sit outside your house for hours until you are ready to leave, especially when they might also be turning down additional work elsewhere. I'm not sure how taxi firms in your part of the world work, but around these parts they like to get as many jobs in as they can, and leave sleeping until after their shifts.
 
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