Availability of accessible rail replacement coaches

[Bletchleyite]

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.

The only other workaround I can see is perhaps for the Government, ATOC or whoever to buy or lease a fleet of accessible vehicles for RRB use (on the basis that you usually don't have all the mainlines out of use) and simply hire coach company drivers to drive them? This model is not unusual for tendered bus services.

 

[Deafdoggie]

The only other workaround I can see is perhaps for the Government, ATOC or whoever to buy or lease a fleet of accessible vehicles for RRB use (on the basis that you usually don't have all the mainlines out of use) and simply hire coach company drivers to drive them? This model is not unusual for tendered bus services.

Possible, but I suspect costly. The coaches will need to be driven around to the correct place for their next job. They’ll need to be stored somewhere. They’ll need a “legal owner and operator” who is responsible for safety checks, servicing and MOTs. This will all, more than likely, cost more than paying coach operators to get new coaches.

 

[Qwerty133]

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

Even if there was a large number of coaches that have been sat in fields for several years it is doubtful that many of them could be returned to active service without significant works if at all and those that do return would probably be of dubious reliability at best.

 

[richw]

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

I was sent photos about 3 months ago, since those photos at least 10 have been towed out and returned to roadworthy condition, there was around 30 in the photo I was sent

 

[Robertj21a]

I was sent photos about 3 months ago, since those photos at least 10 have been towed out and returned to roadworthy condition, there was around 30 in the photo I was sent

Thanks. I'm aware of some Caetanos as dealer stock but didn't think that they had been there for years.

 

[richw]

Thanks. I'm aware of some Caetanos as dealer stock but didn't think that they had been there for years.

the ones I was sent in a photo had apparently been in situ since 2014 when they were withdrawn!

 

[The Planner]

The only other workaround I can see is perhaps for the Government, ATOC or whoever to buy or lease a fleet of accessible vehicles for RRB use (on the basis that you usually don't have all the mainlines out of use) and simply hire coach company drivers to drive them? This model is not unusual for tendered bus services.

Possible, but I suspect costly. The coaches will need to be driven around to the correct place for their next job. They’ll need to be stored somewhere. They’ll need a “legal owner and operator” who is responsible for safety checks, servicing and MOTs. This will all, more than likely, cost more than paying coach operators to get new coaches.

TOCs would probably like that, as their track access charges would be lowered as they wouldn't receive the RRB element of Schedule 4 compensation and the risk is removed from them.

 

[Taunton]

I presume there are a number of current situations where compliantly accessible vehicles are provided. For those who manage these operations, to what extent are the facilities actually used by those who require them.

Likewise, there are the current situations where such vehicles are not provided. When a passenger requiring these facilities presents themselves, what is the procedure.

 

[Deafdoggie]

I presume there are a number of current situations where compliantly accessible vehicles are provided. For those who manage these operations, to what extent are the facilities actually used by those who require them.

Likewise, there are the current situations where such vehicles are not provided. When a passenger requiring these facilities presents themselves, what is the procedure.

I’m not aware there are any official figures. But the number of people turning up in a wheelchair is very low. The number of people requiring a toilet onboard is much higher. The number of people who can’t read the bit of paper in the window to say where it is calling is much higher. Because wheelchairs are a disability that can be seen though, that’s the one that grabs all the attention. The hidden disabilities get overlooked and everyone is anxious to provide wheelchair spaces-needed or not, regardless of cost. This is why RRB will cease. A more sensible approach might ensure RRBs continue.
Current procedure is that if a wheelchair passenger turns up, and they are unable to board (some wheelchair passengers can leave their chair and board with assistance) the driver will contact control and a wheelchair accessible vehicle will be dispatched. It just depends where this is as to how long it takes.
Just like travelling by train, many disabled passengers book in advance, so then an appropriate vehicle can be ready and waiting.
At the moment the only ‘problem’ are those disabled passengers that can’t leave their chairs and haven’t booked in advance. We’re not taking massive numbers here. I’m not saying we should ignore them. I’m just saying I don’t think it’s worth abolishing RRB for everyone for.

 

[Snow1964]

Although the focus has been on physical disability (very little seems to be discussed about other disabilities eg blind) there are other problems pending.

From October 2020 all buses and coaches (and trucks over 7.5t) have to be minimum euroVI to operate in London, so wouldn’t be able to use a compliant (but euroV) vehicle on a route like Surbiton-Woking. There are a lot of outer suburban routes that will be affected

Short term I can see a lot of pairing (that is 2 or 3 replacements running together as one service), where just one vehicle is compliant and others are just extra capacity. Probably be fixed by numbering them as 1, 1A, 1B then 2, 2A etc rather than 1, 2, 3, 4...

 

[Robertj21a]

Although the focus has been on physical disability (very little seems to be discussed about other disabilities eg blind) there are other problems pending.

From October 2020 all buses and coaches (and trucks over 7.5t) have to be minimum euroVI to operate in London, so wouldn’t be able to use a compliant (but euroV) vehicle on a route like Surbiton-Woking. There are a lot of outer suburban routes that will be affected

Short term I can see a lot of pairing (that is 2 or 3 replacements running together as one service), where just one vehicle is compliant and others are just extra capacity. Probably be fixed by numbering them as 1, 1A, 1B then 2, 2A etc rather than 1, 2, 3, 4...

Vehicles in regular use on such routes can be upgraded to Euro6.

 

[Bletchleyite]

Short term I can see a lot of pairing (that is 2 or 3 replacements running together as one service), where just one vehicle is compliant and others are just extra capacity. Probably be fixed by numbering them as 1, 1A, 1B then 2, 2A etc rather than 1, 2, 3, 4...

This seems a sensible line, with the accessible vehicle potentially not needing to be a coach but instead a small bus, either one of those specifically designed ones or something like an Optare Solo.

A sensible world will see the law changed so that to replace any given timetabled train service there must be the same amount of wheelchair capacity as the train had, that's all.

The taller wheelchair user posting upthread is an interesting issue and may be better solved by changing the law on minimum headroom on wheelchair accessible taxis than with regard to RRBs. Of course, tall people encounter problems all over the network whether in a wheelchair or not - it has certainly caused me back pain being crammed into a tight pitch seat before.

The interesting question is what if the law is changed. What are the penalties for infringement? For years the likes of B&Q simply accepted being periodically prosecuted for Sunday trading because they made more than the fines. Could the railway simply continue as before and accept the fines until such time as it's possible to obtain accessible coaches more easily?

 

[kingqueen]

The accessibility regulations don't just deal with wheelchair access. In fact, wheelchair access forms only one part of the regulations. Others include:

A regulated public service vehicle shall be fitted with a route number display and a destination display in the following positions
(a) on the front of the vehicle, as close as practicable to the part of the windscreen which is
within the drivers field of vision; and
(b) on the near-side of the vehicle adjacent to the entrance...
A regulated public service vehicle shall be fitted with a route number display on the rear of the
vehicle.

Compliance with the regulations will also improve visibility of the route description etc. Also handrails, seat dimensions, corridor widths and grip, etc. So it is by no means focused purely on wheelchair users.

The penalties are theoretically severe. There's a theoretical £2,500 fine and a criminal record for each person or organisation that uses an inaccessible vehicle or causes or permits such a vehicle to be used, including through neglect.

Theoretically. In practice nobody and no organisation has ever been prosecuted for this offence.

 

[Bletchleyite]

It's clear with that that nobody thought of RRBs in setting those rules. For instance, a rear number display is of no relevance to a service that doesn't have a number such as a RRB.

 

[kingqueen]

It's clear with that that nobody thought of RRBs in setting those rules. For instance, a rear number display is of no relevance to a service that doesn't have a number such as a RRB.

That's largely true, I agree. Mind you, many school buses don't have numbers either, yet they were explicitly thought about when the rules were first implemented.

 

[Bletchleyite]

That's largely true, I agree. Mind you, many school buses don't have numbers either, yet they were explicitly thought about when the rules were first implemented.

The rules don't apply to them if they are not open for public use, as I understand it.

 

[kingqueen]

The rules don't apply to them if they are not open for public use, as I understand it.

They apply to school buses if any one person on that bus has had money paid for their right to travel on it. So if the local authority or bus company sells spare seats to pupils who aren't entitled to free school transport, the vehicle is subject to the accessibility regulations.

 

[richw]

That's largely true, I agree. Mind you, many school buses don't have numbers either, yet they were explicitly thought about when the rules were first implemented.

every school bus here has a number open and closed . Mostly displayed in a laminate card in windscreen here. Helps the kids know they’re getting on the right bus. They consist of 3 letters (schools 3 letter code) and 3 numbers ( the particular route to that school)
Eg abc001 is route 1 to school Abc. Def001 is route 1 to school def.

 

[Deafdoggie]

every school bus here has a number open and closed . Mostly displayed in a laminate card in windscreen here. Helps the kids know they’re getting on the right bus. They consist of 3 letters (schools 3 letter code) and 3 numbers ( the particular route to that school)
Eg abc001 is route 1 to school Abc. Def001 is route 1 to school def.

That’s just at the request of the school. It’s not compliant with disability regulations

 

[richw]

A further exemption has been issued

 

[Flying Snail]

A further exemption has been issued

LOL

All that faff and bureaucracy for 3 months, at least one of which will be passed before they even review the forms. What do they think will be different in April from now that will make their ridiculous requirement for vehicles that do not exist to materialise out of thin air any more viable?

 

[richw]

LOL

All that faff and bureaucracy for 3 months, at least one of which will be passed before they even review the forms. What do they think will be different in April from now that will make their ridiculous requirement for vehicles that do not exist to materialise out of thin air any more viable?

exactly as all of us living in the real world know there ain’t enough psvar vehicles about and available. Take the Devon rail replacement last few weekends. Needed approx 75 vehicles, of which less than 20 were psvar, it may have been as low as 10 psvar! Simply isn’t the vehicles about

 

[kingqueen]

December, rail minister says: "I also understand there is more work needed to prevent the practice of operating rail replacement bus and coach services that are not compliant with relevant accessibility regulations. Currently I am only willing to grant a short one-month extension for the period from 1 January 2020 to 31 January 2020 to ensure that passengers are not left without rail replacement services during this time."
January: extends to May without any further statement.

 

[Flying Snail]

December, rail minister says: "I also understand there is more work needed to prevent the practice of operating rail replacement bus and coach services that are not compliant with relevant accessibility regulations. Currently I am only willing to grant a short one-month extension for the period from 1 January 2020 to 31 January 2020 to ensure that passengers are not left without rail replacement services during this time."
January: extends to May without any further statement.

When "more work" really means a vast investment from a disparate group of businesses that have nothing to gain from said investment what do you really expect?

The options here are;

1. Stick to an unrealistic dogma, that even if fully implemented will functionally benefit a minuscule number of people, which is going to render many parts of the country without any functional public transport on a rolling basis for an indefinite period.

2. Accept reality and withdraw this unworkable requirement before a significant number of disadvantaged people are unfairly punished on the alter of disability virtue signalling.

3. Spend a vast amount of money and resources on procuring and operating a national fleet of accessible RRB coaches that will rarely if ever actually carry a wheelchair.

 

[richw]

A quick look at various coach selling advertisement sites, cheapest PSVAR 50+ seats is 75000 + VAT.
A suitable non psvar coach 50+ seats plenty of choice sub £15000 + VAT.
Rail replacement is paid around £65 an hour (or a pence per mile rate, whichever is higher). Why pay 5 times as much for a vehicle for the same rate if you can get away with it. Rail isn’t lucrative enough and most operators simply use it to fill gaps in work and availability. Why would they ever invest such a big sum for what is effectively low paid side work.

 

[kingqueen]

I expected two things, I guess

1) the rail minister to have not implied that he was only intending on a one month extension and that under protest, then the DFT offering a further three-month extension without any further announcement. As you say, assuming one accepts the premise that an extension was necessary in the first place, a one month extension was always not going to be of any benefit to anybody, and pending that it was is disingenuous and silly.

2) all bodies concerned to understand, prepare for and comply with the law; failure to do so resulted in this situation (whether you or anybody else agrees with the law or not.)

 

[Flying Snail]

A quick look at various coach selling advertisement sites, cheapest PSVAR 50+ seats is 75000 + VAT.
A suitable non psvar coach 50+ seats plenty of choice sub £15000 + VAT.
Rail replacement is paid around £65 an hour (or a pence per mile rate, whichever is higher). Why pay 5 times as much for a vehicle for the same rate if you can get away with it. Rail isn’t lucrative enough and most operators simply use it to fill gaps in work and availability. Why would they ever invest such a big sum for what is effectively low paid side work.

If it was consistent work then it would be at least worth looking at but RRB work is far too transitory for operators to invest any substantial capital in up-specifying their fleet for it, particularly as that investment will be valueless for the rest of the work they are likely to get out of that coach. An operator could spend hundreds of thousands on some higher spec coaches and get only a handful of weekends of work in their area over the next few years, the RRB work could pay £500 an hour and that would still be uneconomical.

 

[Flying Snail]

I expected two things, I guess

1) the rail minister to have not implied that he was only intending on a one month extension and that under protest, then the DFT offering a further three-month extension without any further announcement. As you say, assuming one accepts the premise that an extension was necessary in the first place, a one month extension was always not going to be of any benefit to anybody, and pending that it was is disingenuous and silly.

2) all bodies concerned to understand, prepare for and comply with the law; failure to do so resulted in this situation (whether you or anybody else agrees with the law or not.)

You really had an expectation that a politician, a tory minister at that, would not be talking out their arse, really?

The only way to "comply with the law" as you put it is to massively curtail and suspend RRB provision, would you rather that happen instead of continuing as things currently stand? If you can't have a fleet of accessible buses running just in case yo may wish to use one someday then nobody should be able to travel?

 

[kingqueen]

You really had an expectation that a politician, a tory minister at that, would not be talking out their arse, really?

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.

The only way to "comply with the law" as you put it is to massively curtail and suspend RRB provision

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.

 

[TUC]

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.