Guidance

DPTAC position on the accessibility of coach services

Published 20 January 2021

Applies to England, Scotland and Wales

Disabled people’s right to use coach services

The Disabled Persons Transport Advisory Committee (DPTAC) believes that coach travel, like all other forms of public transport, should be accessible to disabled people. Indeed, there are good economic reasons for the industry to maximise the accessibility of services, as the age group who travel the most miles by coach is the over-70s, a growing age group with the highest levels of disability.

DPTAC was pleased that, when the Public Service Vehicle Access Regulations (PSVAR) were extended to cover coaches, the main providers of scheduled services moved quite rapidly to use compliant vehicles. It was our hope that once these coaches had reached the end of their life in providing scheduled services, they would enter the secondhand market and contribute to wider accessibility in the overall coach market. Ideally, this would stimulate increased demand for PSVAR-compliant coaches, with operators choosing to purchase more vehicles.

Regrettably, this appears not to have been the case. In a number of instances, accessibility features required for PSVAR have been removed when vehicles are no longer used on scheduled services. According to data gathered by the Rail Delivery Group (RDG), there are only 600 PSVAR compliant coaches available in the ‘for-hire’ sector out of more than 25,000 vehicles currently in commercial use.

DPTAC is disappointed that the ‘for-hire’ coach sector is out of step with the rest of the transport industry in its reluctance to meet the needs of disabled passengers. For a variety of reasons relating to the economics of the industry, as well as the lack of regulatory pressure, the industry appears to have made no significant effort to improve accessibility. Government intervention is now essential to drive change.

PSVAR coach services

PSVAR brought a number of improvements to the accessibility of coach services. Most significantly, it included the provision of a lift which allows wheelchair users to travel on coaches when formerly this was impossible.

However, we acknowledge that there are some unfortunate limitations to the accessibility of PSVAR coaches, which may have inhibited their wider adoption by coach companies. Most notably, the steps at the entrance are a barrier for some people with mobility impairments. Although efforts have been made to make them shallower, they appear to be an insuperable barrier for some people. Others may be able to struggle up them when absolutely necessary, but will generally avoid coach travel because of the effort involved and the uncertainty of access.

This problem was acknowledged when the PSVAR were passed and there were some suggestions that a passenger could be allowed to stand on the lift to board the coach. As far as DPTAC is aware, this has not been tried despite the fact that similar lifts are frequently used by standing passengers using community transport services, NHS mobile clinics and Ambulifts at airports.

There are also 2 significant variations from the regulations that apply to buses. For coaches, there is no obligation to include seats with space for a guide dog to sit at the passenger’s feet, and either the wheelchair space, or more likely the platform, does not have to be compatible with the reference wheelchair. In addition, the space required to deploy the ramp external to the coach is such that there are many passenger pick-up points where wheelchair users are unable to board.

Increasing the numbers of PSVAR coaches in service

From 1 January 2020, it became unlawful to use a non-PSVAR compliant coach on a scheduled service for which a charge is made. This should have included those home to school transport services, where some pupils are charged, and rail replacement services. This change should have helped to drive further investment in PSVAR-compliant coaches and a move to a more accessible fleet.

The commissioners of home to school transport did not give sufficient consideration to their legal obligations and failed to include PSVAR compliance in their tendering requirements. Operators also failed to recognise their obligations and did not target adequate investment in securing compliant vehicles.

The contractors of rail replacement services had operated under the belief that their services were exempt and it was only after the Office for Road and Rail (ORR) issued revised guidance in September 2019 that they had to contract for PSVAR compliant coaches.

It was clear there were insufficient PSVAR coaches in service to achieve compliance with the regulations when such vehicles became mandatory in January 2020. The Department for Transport (DfT) issued temporary exemptions of up to 4 years to the operators of home to school services. The first of these will expire in July 2021. A temporary exemption for rail replacement services will expire on 30 September 2021.

It has been estimated that lifting the exemption for home to school services will require the introduction of 4,000 to 6,000 PSVAR compliant coaches. Such an increase will mean that around 20% of all coaches in the ‘for-hire’ sector are compliant. DPTAC is conscious that investment in PSVAR coaches on this scale is likely to ‘lock-in’ the current PSVAR standards for the foreseeable future. That will include the weaknesses in the current standards noted above.

For that reason, DPTAC is calling on the government to use the period of the current exemptions to rapidly explore whether alternatives can be quickly developed which offer an improved level of accessibility. The current coronavirus (COVID-19) pandemic means that coach operators are cautious about investing in new vehicles and manufacturing capacity is reduced as a result of social distancing rules, so there appears to be little prospect of rapid change in the make-up of the fleet over the next few months.

Review of alternative design options for an accessible coach

To explore whether a more accessible design for a coach is feasible, DPTAC believes that the current period of temporary exemptions can be usefully used to carry out a quick investigation, as follows:

  • DfT should quickly (within a matter of weeks) convene a panel with representatives of the coach industry, manufacturers and disabled people to draw up a research specification
  • DfT should invite outline proposals to achieve the requirements of the specification. This, too, should be a relatively short process of a few months
  • the panel should judge the proposals submitted with funding being made available for a maximum of 2 proposals to be worked up into full designs, with a view to them providing the basis for a revised set of PSVAR regulations.

The time set aside for this process should not exceed 12 months. At any stage, the panel may conclude that no significant improvements on the current PSVAR are available and abandon the process.

Towards a fully accessible coach fleet

At the start of the process detailed above, the DfT should commit to providing parliamentary time for the adoption of a revised set of accessibility regulations for coaches. This should include: setting challenging timetables for the new regulations to become mandatory for public services, and including home to school transport and rail replacement services.

In the event that no proposals for revisions of PSVAR are forthcoming, the government should publish a timetable for the ending of the temporary exemptions.

During the period of the review, the government should ensure (ideally through a voluntary agreement with the coach industry) that no accessibility features are removed from any existing coach which is withdrawn from use on scheduled services but continues in other commercial use.

DPTAC believes that the government should, in due course, remove the exemption from PSVAR of the whole of the ‘for-hire’ sector. This alone will ensure that disabled people are no longer excluded from this important transport provision.

DPTAC is conscious that the investment required to achieve full accessibility across the coach industry will be considerable. Government will have to set timetables that are challenging, but not unachievable.

We are also aware that some firms are able to undertake conversion work to make existing vehicles compatible with PSVAR standards at a fraction of the cost of purchasing a new vehicle. We have heard concerns from manufacturers that these conversions may risk compromising the structural integrity of the vehicle.

DPTAC does not have the expertise to evaluate the legitimacy of these concerns but the option of conversion must be evaluated fully. We advise the DfT to work with the Driver and Vehicle Standards Agency (DVSA) to investigate the scope for achieving compliance through the conversion of existing vehicles and to take account of the progress which can be made in this way when setting deadlines for compliance with PSVAR.

Separately, DPTAC has submitted advice to DfT calling for the exemptions for replacement vehicles for planned disruptions to rail services to be limited to just 4 years. We believe this will send an important message to the coach industry that the government is determined to make coach services accessible to disabled people. By using long-term contracts with coach operators, rail companies will be able to give coach companies the confidence to invest in compliant vehicles.

Home to school transport provision

DPTAC believes it is important that home to school transport services provide an accessible and inclusive service. It is vital that disabled young people have the opportunity to mix with their peers and learn to use public transport services. The current situation where they are excluded from mainstream transport and have to use separate specialist provision is unacceptable and likely to affect their confidence in using public transport as they transition to adulthood and enter the workforce.

Local authorities and schools that have allowed the current inaccessible arrangements to persist for years, ignoring the increasing accessibility of public transport vehicles, have done a serious disservice to a generation of disabled young people.

DPTAC calls on all those involved in the procurement of home to school transport services to commit to moving to accessible provision as soon as practical.

We question whether large 48-seater coaches are always the best way to transport pupils to school. Using such large vehicles in more sparsely populated parts of the country will necessitate long journeys and early pick-up times to ensure a large number of pick-up points to use the vehicle at capacity.

Smaller vehicles making few pick-ups could result in more direct, and therefore quicker, journeys. Such vehicles might have a role to play in public transport provision in rural areas outside school journey times.

We suggest the current situation might present a useful opportunity for the DfT, Department for Education, Ministry of Housing, Communities and Local Government, and local authorities to explore alternative accessible arrangements that could bring wider benefits.