Availability of accessible rail replacement coaches

33017

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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.
The ORR have indicated all rail replacement transport whether emergency or planned is subject to PSVAR.

There is plenty of rail replacement work over 30/35 miles and I have always been advised by the road transport section coaches must be used for this work as buses are not allowed. This may be a company standard but similar advice has been received from local bus firms when contacted as a last resort. Maybe it’s permitted with a change of driver en-route (not very practical).

One class of vehicle which is permitted to run without being PSVAR compliant is a minibus with 22 seats or fewer, but they can’t exactly shift large numbers.
 
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djw

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There is plenty of rail replacement work over 30/35 miles and I have always been advised by the road transport section coaches must be used for this work as buses are not allowed. This may be a company standard but similar advice has been received from local bus firms when contacted as a last resort. Maybe it’s permitted with a change of driver en-route (not very practical).
This is likely down to the 50km limit for operation on domestic drivers' hours without a tachograph. Most buses are not used above 50km and are not tachograph fitted. Drivers working a mixture of EU hours and domestic hours work introduces all sorts of complexity, not least a likelihood of fewer hours available in total than if they stay purely on domestic hours work.

My understanding is that most buses are not tachograph fitted and most bus drivers (and their employers) expect to be solely on domestic hours work.
 

philthetube

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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.
For industry read tocs, years ago many did not know if they would have franchises no so could not be expected to spend preparing.
 

Robertj21a

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The ORR have indicated all rail replacement transport whether emergency or planned is subject to PSVAR.

There is plenty of rail replacement work over 30/35 miles and I have always been advised by the road transport section coaches must be used for this work as buses are not allowed. This may be a company standard but similar advice has been received from local bus firms when contacted as a last resort. Maybe it’s permitted with a change of driver en-route (not very practical).

One class of vehicle which is permitted to run without being PSVAR compliant is a minibus with 22 seats or fewer, but they can’t exactly shift large numbers.
The documents I saw specifically excluded emergency situations.
 

richw

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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.
Over 50km (approx 35 miles) requires a tacho. Very few service buses have a tacho. I think of our service bus fleet here, out of approx 220 buses less than 10 have tacho fitted. If rail requires a tacho for all work then it would rule out service buses (unsure if it’s domestic or EU rules for RR, never done it)
 

Deafdoggie

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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........
It doesn’t matter if it’s planned or not, bus companies simply don’t have spare buses sat around. Sunday sees a few spare but most have work done on them then as they are already off the road. And where are you producing drivers from?


Over 50km (approx 35 miles) requires a tacho. Very few service buses have a tacho. I think of our service bus fleet here, out of approx 220 buses less than 10 have tacho fitted. If rail requires a tacho for all work then it would rule out service buses (unsure if it’s domestic or EU rules for RR, never done it)
EU hours apply for RRB and therefore tacho required. It is possible (but complex and messy) to do it on ‘paper records’ if the bus doesn’t have a tacho, but given this complexity most operators avoid it as it simply isn’t worth it.
Drivers are then stuck with EU driving hours for 14 days so most bus shifts don’t suit them. Another reason operators aren’t keen, and drivers neither as it means their hours, and therefore pay, is less.



The complexity of a coach company providing drivers and a bus company providing buses (as suggested upthread) is just so complex as to be not worth being considering. Even if there were these mythical spare buses.

The harsh reality is that RRB is just a bit extra work for coach companies. And work that doesn’t even pay all that well. they can take it or leave it. If you force them to spend hundreds of thousands on coaches they have no other need for, they’ll simply leave it. It’s not they’ve been ignoring this problem, they just have no need to be part of the solution. Either they can use the coaches they have now on RRB or they can’t. If they can’t they don’t do RRB and that’s the end of the matter. There isn’t a coach company out there that waits for RRB work to come in, they’ll manage happily without it. Anyone who thinks they’ll suddenly buy a fleet of new coaches is wrong.

The rail industry will have to solve this, and there are only three possible solutions
1) Convince government that all RRBs don’t need to have wheelchair access.
2) Recast timetables so that there are less trains and long periods when no trains at all, to allow maintainence to be carried out without altering the timetable.
3) Offering no replacement to passengers when trains cancelled. Adopting a hardball ‘tough’ approach.
Options 2 & 3 won’t go down well with the public, and will more than likely force to government into doing option 1. The common sense option all along.
 

Dai Corner

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Indeed Deafdoggie.

The problem should have been framed as 'How can we ensure there is good provision for passengers with reduced mobility when trains are replaced by road transport?' not 'how can we get the industry to use only PSVAR compliant vehicles on rail-replacement work?'

Make the case, then let the industry provide the best solution at a price the politicians are prepared to pay.
 

richw

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It takes 10-12 coaches to replace a 8-10 car train. How many disabled spaces are on each of these trains? Why not a like for like capacity?
 

Robertj21a

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It doesn’t matter if it’s planned or not, bus companies simply don’t have spare buses sat around. Sunday sees a few spare but most have work done on them then as they are already off the road. And where are you producing drivers from?




EU hours apply for RRB and therefore tacho required. It is possible (but complex and messy) to do it on ‘paper records’ if the bus doesn’t have a tacho, but given this complexity most operators avoid it as it simply isn’t worth it.
Drivers are then stuck with EU driving hours for 14 days so most bus shifts don’t suit them. Another reason operators aren’t keen, and drivers neither as it means their hours, and therefore pay, is less.



The complexity of a coach company providing drivers and a bus company providing buses (as suggested upthread) is just so complex as to be not worth being considering. Even if there were these mythical spare buses.

The harsh reality is that RRB is just a bit extra work for coach companies. And work that doesn’t even pay all that well. they can take it or leave it. If you force them to spend hundreds of thousands on coaches they have no other need for, they’ll simply leave it. It’s not they’ve been ignoring this problem, they just have no need to be part of the solution. Either they can use the coaches they have now on RRB or they can’t. If they can’t they don’t do RRB and that’s the end of the matter. There isn’t a coach company out there that waits for RRB work to come in, they’ll manage happily without it. Anyone who thinks they’ll suddenly buy a fleet of new coaches is wrong.

The rail industry will have to solve this, and there are only three possible solutions
1) Convince government that all RRBs don’t need to have wheelchair access.
2) Recast timetables so that there are less trains and long periods when no trains at all, to allow maintainence to be carried out without altering the timetable.
3) Offering no replacement to passengers when trains cancelled. Adopting a hardball ‘tough’ approach.
Options 2 & 3 won’t go down well with the public, and will more than likely force to government into doing option 1. The common sense option all along.

A lot of all this can also be dependent on how many vehicles are required for any particular RR. Some rural train replacements may only require, say, 6-8 vehicles and other main line train replacements might need, say, 40+ vehicles. The first scenario may have a range of solutions whereas the second probably doesn't.
I'm a bit puzzled as to how RR is accomplished in the London area if all drivers have to operate under EU hours. There can be dozens of deckers needed, drawn from the normal London (TfL) fleets and supplemented by the likes of Brighton, Reading, Stagecoach etc. I can't see that all of these will have tachos, nor drivers who work to EU regulations. Are you quite sure that EU rules apply to all RRs ?
 

richw

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A lot of all this can also be dependent on how many vehicles are required for any particular RR. Some rural train replacements may only require, say, 6-8 vehicles and other main line train replacements might need, say, 40+ vehicles
the recent Plymouth to Exeter blockade had approx 75 vehicles. They had wheelchair taxis on standby at each station
 

Robertj21a

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the recent Plymouth to Exeter blockade had approx 75 vehicles. They had wheelchair taxis on standby at each station
I believe that some of the Southern RR work from Three Bridges has needed something over 100 vehicles (mostly double deck buses).
Other small RR work can only need 3- 4 vehicles.
 

HH

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Too many posts to read through the entire thread, but here are some points:

1. Most RR buses are old and not PSVAR compliant; when I say most I mean 99%. New buses are in use on the busiest bus routes.
2. The leading coach manufacturer has recently announced that its best selling coach would be PSVAR from Jan 2020, which tells you all about what has been built to date.
3. TOCs were given advice by the ORR that RR buses would be exempt from PSVAR. ORR have had to change their position after being challenged, but it has meant that TOCs haven't had very much time to react. Hence the DfT's derogation (which currently runs out on Friday).
4. TOCs are not in a position to demand anything of bus/coach companies. Yes, it's a nice earner for bus companies, but only when they can use buses that would otherwise be sitting idle. They're not going to buy new buses purely for RR work.

I can't see any alternative but a further and longer derogation, as TOCs simply will not be able to hire only PSVAR buses/coaches and carry all the passengers they need to; they are simply not available. I expect that, in return for this, DfT will put some additional requirements in, like supply of X% PSVAR buses and/or use of taxis. Well, at least that would be the sensible solution.
 

Flying Snail

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A lot of all this can also be dependent on how many vehicles are required for any particular RR. Some rural train replacements may only require, say, 6-8 vehicles and other main line train replacements might need, say, 40+ vehicles. The first scenario may have a range of solutions whereas the second probably doesn't.
I'm a bit puzzled as to how RR is accomplished in the London area if all drivers have to operate under EU hours. There can be dozens of deckers needed, drawn from the normal London (TfL) fleets and supplemented by the likes of Brighton, Reading, Stagecoach etc. I can't see that all of these will have tachos, nor drivers who work to EU regulations. Are you quite sure that EU rules apply to all RRs ?
I would say it is borderline on RR work being fully compliant with the rules for being in scope for domestic driving regs. The requirement is for it to be scheduled work under 50kms, there being no requirement for drivers to record their work but should have a service board on them which accurately sets out their duty and is a requirement for employer to keep a record of.

From observation some RR work is obviously boarded but others seem to be run more ad-hoc with local controllers assigning and changing duties in line with demand which would not comply with domestic rules as no boards would exist that reflected the work actually done.
 

MarlowDonkey

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I would say it is borderline on RR work being fully compliant with the rules for being in scope for domestic driving regs.
Perhaps those devising all these regulations with side effects should be locked in a room until they came up with a solution which didn't require the complete closure of public transport operations whenever a railway line had to be closed for maintenance. That could be provision of a limited number of parallel taxis or using buses for longer journeys. Just don't close down the options with over prescriptive regulation.
 

Robertj21a

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Too many posts to read through the entire thread, but here are some points:

1. Most RR buses are old and not PSVAR compliant; when I say most I mean 99%. New buses are in use on the busiest bus routes.
2. The leading coach manufacturer has recently announced that its best selling coach would be PSVAR from Jan 2020, which tells you all about what has been built to date.
3. TOCs were given advice by the ORR that RR buses would be exempt from PSVAR. ORR have had to change their position after being challenged, but it has meant that TOCs haven't had very much time to react. Hence the DfT's derogation (which currently runs out on Friday).
4. TOCs are not in a position to demand anything of bus/coach companies. Yes, it's a nice earner for bus companies, but only when they can use buses that would otherwise be sitting idle. They're not going to buy new buses purely for RR work.

I can't see any alternative but a further and longer derogation, as TOCs simply will not be able to hire only PSVAR buses/coaches and carry all the passengers they need to; they are simply not available. I expect that, in return for this, DfT will put some additional requirements in, like supply of X% PSVAR buses and/or use of taxis. Well, at least that would be the sensible solution.
When you say that 99% of buses are old and non compliant I assume you mean coaches. Buses are now 100% required to be compliant.
 

Bikeman78

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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.
Cardiff Bus have done rail replacement work for ATW in the past; not sure if they do any for TFW. They have a few spare vehicles on Saturdays, i.e. those that do peak extras and school runs on weekdays. As you say, it won't work for unplanned closures, certainly not on weekdays.
 

Bletchleyite

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1) Convince government that all RRBs don’t need to have wheelchair access.
A change in the law to permit this (and, to be honest, duplicates) is a sensible way to go in my view. It could be something like "If a coach service is provided by multiple vehicles which depart at the same time, only one such vehicle must be accessible, and this may be provided by a separate dedicated vehicle if this is more convenient to the operator". So 5 conventional coaches plus a taxi = fine.
 

Dai Corner

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A change in the law to permit this (and, to be honest, duplicates) is a sensible way to go in my view. It could be something like "If a coach service is provided by multiple vehicles which depart at the same time, only one such vehicle must be accessible, and this may be provided by a separate dedicated vehicle if this is more convenient to the operator". So 5 conventional coaches plus a taxi = fine.
Sounds like a sensible solution.

They could even keep the taxis busy when they weren't required for wheelchairs by offering First Class passengers a fast, direct ride to their destination station!
 

Bletchleyite

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Sounds like a sensible solution.

They could even keep the taxis busy when they weren't required for wheelchairs by offering First Class passengers a fast, direct ride to their destination station!
:)

To me the key is that the service is accessible, not that each vehicle is. Requiring each coach in a convoy of 5 replacing an InterCity train to have a wheelchair space when the train it replaces has only one in the whole train is just silly, really, and replacing all the vehicles with services buses is equally silly because it discriminates against those with other disabilities such as frequent toilet need or back problems which would make multi-hour journeys in a service bus impossible.

I would probably also write something in for ad-hoc services where there is no timetable, but I'm not quite sure what, but again it wouldn't require all vehicles to be accessible but simply for anyone who cannot for whatever reason board the vehicles to be carried within a reasonable[1] length of time of presenting themselves to be carried, and further exempting if the operator can prove they have made an adequate and continuing attempt to obtain vehicles and have been completely unable to obtain them despite this effort.

[1] A time commensurate with the waiting time for any other walk-up passenger, so if there's an hour's queue for anyone to get on a bus in an emergency situation, a wheelchair user may have to wait an hour, too.
 

JonathanH

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As a matter of interest, aside from the practicalities, why is there no legislation to require universal toilets in coaches (where a toilet is fitted)?
 

Flying Snail

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As a matter of interest, aside from the practicalities, why is there no legislation to require universal toilets in coaches (where a toilet is fitted)?
Why would there need to be any other reason beyond it being completely impractical?

I'm sorry but it is this sort of nonsense that is the problem, something can't be done but should be legislated for anyway because DISCRIMINATION.

That it is now the norm that a solution to not providing mass transport that is 100% accessible is to just withdraw or not provide the service for anyone is just ridiculously wrong. The people excluded from the service are still excluded, they just get to be joined by everybody else.
 

richw

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I would say it is borderline on RR work being fully compliant with the rules for being in scope for domestic driving regs.
Putting the interpretation that psvar is required would push it more to being domestic if it meets the 50km rule. Colleagues who did Plymouth to Tiverton recently knew exactly what time they were From both ends days in advance. But a friend who owns a coach company is on standby today and thus has no running board or planned timetable so would be EU.
 

Bletchleyite

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As a matter of interest, aside from the practicalities, why is there no legislation to require universal toilets in coaches (where a toilet is fitted)?
A coach is too small to have one, quite simply, and due to the law it isn't possible to increase the size of a coach to make one practical[1]. And a coach can arrange to stop at motorway services, garages etc where there is always one provided and very often a better one than you could have on a vehicle, e.g. a Changing Places facility. Yes, I suppose a train could stop at a station as well, but a coach can do this completely without delay to other coaches whereas a train mostly can't do it without delaying other trains so it is impractical.

I'd suggest that refusing such a stop should be considered discrimination, though.

Where you could fit one in is a widebody airliner, though, and the mind boggles as to why this isn't a requirement, particularly as you can hardly stop for a quick wee when at 40,000ft over the Atlantic.

[1] While you possibly could fit one downstairs in a double decker with most seats upstairs, the width of a coach is an issue.
 

Cesarcollie

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This is likely down to the 50km limit for operation on domestic drivers' hours without a tachograph. Most buses are not used above 50km and are not tachograph fitted. Drivers working a mixture of EU hours and domestic hours work introduces all sorts of complexity, not least a likelihood of fewer hours available in total than if they stay purely on domestic hours work.

My understanding is that most buses are not tachograph fitted and most bus drivers (and their employers) expect to be solely on domestic hours work.
The rules re drivers hours/tachos are no different on rail replacement to any other. If the work is scheduled and regular and the end to end journey the bus/coach makes is under 50km, domestic rules apply and no tacho is required. Hence buses and bus drivers are often suitable and used.
if the journey is over 50km, EU hours apply. Emergency rail replacement is in theory (arguably ) exempt from hours rules. But once it’s been carried out, the hours worked impact on all the subsequent planned work (private hire etc) that driver is booked onto for his working week. So most companies will still expect it to be achieved compliantly. With EU hours a tacho is required (paper records aren’t a legal alternative unless there’s a fault with the tacho en-route), and as most buses aren’t so fitted, they can’t be used.
 

Robertj21a

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So, as I thought, we have a key difference. Either ALL Rail Replacements need to work under EU rules (which I've questioned already) or it's over 50kms/not scheduled.
Which is it ??
 

PhilStockley

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Which is it ??
The answer is that no-one knows for sure. There are people stating things as fact here that are actually their own interpretation rather than fact.

As a rail replacement practitioner for over 15 years in all capacities, I’ve never seen a definitive statement of law about which rules apply where.

I’ve always adopted the pragmatic view that a timetabled service less than 50km in length can be worked under domestic hours and I think that’s the generally common approach.

My view is that anything longer than 50kms must be worked under EU hours.

I have encountered every possible interpretation of emergency work at various times in various places - some day domestic is okay, others that it must be EU, others that no rules apply. The only one I’m really comfortable with is the middle one, but could I honestly say I’ve never worked an emergency turn under domestic hours? No, I couldn’t

Of course, even if a duty can be worked under domestic hours, coach operators will usually choose to work it under EU hours anyway, because all the rest of their work is EU so it makes the record keeping too complex if they do occasional domestic work. Some operators are more comfortable mixing than others.

I have often found myself in a situation as a supervisor where duties have been prepared under domestic hours, and the buses and bus drivers are ploughing up and down quite happily, but the coaches and coach drivers are needing extra breaks because they’re under instruction to work to EU hours regardless of what the duty says (and that’s one sure fire way to get the bus drivers’ backs up!)

Despite the statements of certainty further up this thread, unless there is a definitive source that has eluded me for the last fifteen years, this will continue to be a matter of interpretation until either the authorities issue a definitive ruling (as they did with PSVAR in the autumn) or until an issue arises that leads to it being tested in the courts - and I doubt any bus or train operator has the stomach for that fight.
 

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