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North East Buses Local Bus Scene Operations, Management & Infrastructure PSV Accessibility Regulations (DDA Regulations) - at a glance

PSV Accessibility Regulations (DDA Regulations) - at a glance

PSV Accessibility Regulations (DDA Regulations) - at a glance

 
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Charles41



474
29 Dec 2019, 3:59 pm #201
I feel it would be a shame if it caused any more family owned firms to go out of business. The North East has lost numerous long standing independent operators in the past five years.

Charles
Charles41
29 Dec 2019, 3:59 pm #201

I feel it would be a shame if it caused any more family owned firms to go out of business. The North East has lost numerous long standing independent operators in the past five years.

Charles

tyresmoke



5,300
30 Dec 2019, 4:10 pm #202
(29 Dec 2019, 11:41 am)Dan To be fair, you didn't have to look far in the trade press, to see this matter being debated, in the months leading up to today.

Initial guidance from the DfT was open to interpretation, which muddied the waters. It was originally suggested that school services which do not take any fares (and hence are not registered bus services that claim BSOG etc), and are instead paid for by an alternate means (either by a local authority or directly from a school), did not have to conform to PSVAR.

If you, as a small business with relatively low profits, did not have to go to the expense of replacing your fleet with newer vehicles which do conform to PSVAR, why would you? Many of these small operators just about cover their costs and provide a small number of people with a wage, and it's Private Hires (school trips to the baths etc) that contribute towards the greater profits of the business.


Some trade press articles to have a read of:
https://cbwmagazine.com/dft-announce-a-t...-services/
https://www.disabilitynewsservice.com/mi...ation-law/
https://app.croneri.co.uk/feature-articl...ules-apply

That's exactly the issue facing many operators in the Tees Valley, in that many school services are paid for by parents either directly to the operator or through the school. It was presumed by many operators that any school service, as Dan says, wasn't registered didn't therefore have to comply to PSVAR. There's been a clause for a while that any service carrying a group of passengers to one point (eg a school/college), organised and advertised by another entity (eg a school/college) and paying one flat fare (eg most school/college services) don't have to be registered and that's what a lot of services run under.
It's only recently (in last few months) come to light that all of these services will have to comply which hasn't left much time to bring in vehicles required. There has already been a few school services dropped that will leave kids stranded, such as Carmel College (through Darlington Council, operated by Enterprise Travel) and Nunthorpe School (Compass Royston). Expect you'll see more and more kids being stranded if this is enforced as tenders get thrown in by coach operators. For those who do invest in compliant vehicles you may see those dipping into service work with potential competition for established operators...

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tyresmoke
30 Dec 2019, 4:10 pm #202

(29 Dec 2019, 11:41 am)Dan To be fair, you didn't have to look far in the trade press, to see this matter being debated, in the months leading up to today.

Initial guidance from the DfT was open to interpretation, which muddied the waters. It was originally suggested that school services which do not take any fares (and hence are not registered bus services that claim BSOG etc), and are instead paid for by an alternate means (either by a local authority or directly from a school), did not have to conform to PSVAR.

If you, as a small business with relatively low profits, did not have to go to the expense of replacing your fleet with newer vehicles which do conform to PSVAR, why would you? Many of these small operators just about cover their costs and provide a small number of people with a wage, and it's Private Hires (school trips to the baths etc) that contribute towards the greater profits of the business.


Some trade press articles to have a read of:
https://cbwmagazine.com/dft-announce-a-t...-services/
https://www.disabilitynewsservice.com/mi...ation-law/
https://app.croneri.co.uk/feature-articl...ules-apply

That's exactly the issue facing many operators in the Tees Valley, in that many school services are paid for by parents either directly to the operator or through the school. It was presumed by many operators that any school service, as Dan says, wasn't registered didn't therefore have to comply to PSVAR. There's been a clause for a while that any service carrying a group of passengers to one point (eg a school/college), organised and advertised by another entity (eg a school/college) and paying one flat fare (eg most school/college services) don't have to be registered and that's what a lot of services run under.
It's only recently (in last few months) come to light that all of these services will have to comply which hasn't left much time to bring in vehicles required. There has already been a few school services dropped that will leave kids stranded, such as Carmel College (through Darlington Council, operated by Enterprise Travel) and Nunthorpe School (Compass Royston). Expect you'll see more and more kids being stranded if this is enforced as tenders get thrown in by coach operators. For those who do invest in compliant vehicles you may see those dipping into service work with potential competition for established operators...


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Service Manager, Coatham Connect

30 Dec 2019, 4:42 pm #203
(30 Dec 2019, 4:10 pm)tyresmoke That's exactly the issue facing many operators in the Tees Valley, in that many school services are paid for by parents either directly to the operator or through the school. It was presumed by many operators that any school service, as Dan says, wasn't registered didn't therefore have to comply to PSVAR. There's been a clause for a while that any service carrying a group of passengers to one point (eg a school/college), organised and advertised by another entity (eg a school/college) and paying one flat fare (eg most school/college services) don't have to be registered and that's what a lot of services run under.
It's only recently (in last few months) come to light that all of these services will have to comply which hasn't left much time to bring in vehicles required. There has already been a few school services dropped that will leave kids stranded, such as Carmel College (through Darlington Council, operated by Enterprise Travel) and Nunthorpe School (Compass Royston). Expect you'll see more and more kids being stranded if this is enforced as tenders get thrown in by coach operators. For those who do invest in compliant vehicles you may see those dipping into service work with potential competition for established operators...

To me, it shouldn't be about whether a service is registered or not, if they carry passengers, they should have to comply. End of.

I personally think the issue still lies with the local authority, sure everyone might have presumed that they wouldn't have to comply, but I would have thought that the local authority would have had their own requirements to make sure that the vehicles they run comply rather than going purely on the lowest price.
streetdeckfan
30 Dec 2019, 4:42 pm #203

(30 Dec 2019, 4:10 pm)tyresmoke That's exactly the issue facing many operators in the Tees Valley, in that many school services are paid for by parents either directly to the operator or through the school. It was presumed by many operators that any school service, as Dan says, wasn't registered didn't therefore have to comply to PSVAR. There's been a clause for a while that any service carrying a group of passengers to one point (eg a school/college), organised and advertised by another entity (eg a school/college) and paying one flat fare (eg most school/college services) don't have to be registered and that's what a lot of services run under.
It's only recently (in last few months) come to light that all of these services will have to comply which hasn't left much time to bring in vehicles required. There has already been a few school services dropped that will leave kids stranded, such as Carmel College (through Darlington Council, operated by Enterprise Travel) and Nunthorpe School (Compass Royston). Expect you'll see more and more kids being stranded if this is enforced as tenders get thrown in by coach operators. For those who do invest in compliant vehicles you may see those dipping into service work with potential competition for established operators...

To me, it shouldn't be about whether a service is registered or not, if they carry passengers, they should have to comply. End of.

I personally think the issue still lies with the local authority, sure everyone might have presumed that they wouldn't have to comply, but I would have thought that the local authority would have had their own requirements to make sure that the vehicles they run comply rather than going purely on the lowest price.

tyresmoke



5,300
30 Dec 2019, 5:31 pm #204
(30 Dec 2019, 4:42 pm)streetdeckfan To me, it shouldn't be about whether a service is registered or not, if they carry passengers, they should have to comply. End of.

I personally think the issue still lies with the local authority, sure everyone might have presumed that they wouldn't have to comply, but I would have thought that the local authority would have had their own requirements to make sure that the vehicles they run comply rather than going purely on the lowest price.

Problem there is a lot of school services these days are not local authority backed - they're private contracts with the schools (or indeed parents) themselves. Majority of local authority contracted school buses will not have to comply as they're used only by kids with passes. Of course the schools etc didn't know anything about PSVAR coming in until local authorities told them a few months ago. Now it's all a bit of a rush to comply - the price of old Levante's has gone through the roof!

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tyresmoke
30 Dec 2019, 5:31 pm #204

(30 Dec 2019, 4:42 pm)streetdeckfan To me, it shouldn't be about whether a service is registered or not, if they carry passengers, they should have to comply. End of.

I personally think the issue still lies with the local authority, sure everyone might have presumed that they wouldn't have to comply, but I would have thought that the local authority would have had their own requirements to make sure that the vehicles they run comply rather than going purely on the lowest price.

Problem there is a lot of school services these days are not local authority backed - they're private contracts with the schools (or indeed parents) themselves. Majority of local authority contracted school buses will not have to comply as they're used only by kids with passes. Of course the schools etc didn't know anything about PSVAR coming in until local authorities told them a few months ago. Now it's all a bit of a rush to comply - the price of old Levante's has gone through the roof!


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Service Manager, Coatham Connect

30 Dec 2019, 5:55 pm #205
(30 Dec 2019, 5:31 pm)tyresmoke Problem there is a lot of school services these days are not local authority backed - they're private contracts with the schools (or indeed parents) themselves. Majority of local authority contracted school buses will not have to comply as they're used only by kids with passes. Of course the schools etc didn't know anything about PSVAR coming in until local authorities told them a few months ago. Now it's all a bit of a rush to comply - the price of old Levante's has gone through the roof!

But then we have to ask why is it, after all these years, they've only in the past few months realised they had to comply?
Was it a case of them hoping that if they didn't say anything, nobody would realise that the regulations weren't specific enough to include that type of work?
Or was it a case of them genuinely not realising that they had to comply because in the past they were excluded?

But like I said above, at the end of the day that shouldn't matter. People don't stop needing accessible buses just because it's paid for by a school or parents
streetdeckfan
30 Dec 2019, 5:55 pm #205

(30 Dec 2019, 5:31 pm)tyresmoke Problem there is a lot of school services these days are not local authority backed - they're private contracts with the schools (or indeed parents) themselves. Majority of local authority contracted school buses will not have to comply as they're used only by kids with passes. Of course the schools etc didn't know anything about PSVAR coming in until local authorities told them a few months ago. Now it's all a bit of a rush to comply - the price of old Levante's has gone through the roof!

But then we have to ask why is it, after all these years, they've only in the past few months realised they had to comply?
Was it a case of them hoping that if they didn't say anything, nobody would realise that the regulations weren't specific enough to include that type of work?
Or was it a case of them genuinely not realising that they had to comply because in the past they were excluded?

But like I said above, at the end of the day that shouldn't matter. People don't stop needing accessible buses just because it's paid for by a school or parents

tyresmoke



5,300
30 Dec 2019, 6:34 pm #206
(30 Dec 2019, 5:55 pm)streetdeckfan But then we have to ask why is it, after all these years, they've only in the past few months realised they had to comply?
Was it a case of them hoping that if they didn't say anything, nobody would realise that the regulations weren't specific enough to include that type of work?
Or was it a case of them genuinely not realising that they had to comply because in the past they were excluded?

But like I said above, at the end of the day that shouldn't matter. People don't stop needing accessible buses just because it's paid for by a school or parents

I think it was a case of literally assuming only registered services would be encompassed by the regulations, and as nobody had said otherwise until a few months ago then everyone thought that was the case. I read it differently in that all fare paying services would be included, but there we go. I didn't expect fares paid off-bus would be included, eg private schools & rail replacement.
In the last hour there's been an announcement that PSVAR has been delayed until 31st July, to cover the rest of 2019/20 school year, for home to school services only. Rail replacement will still have to comply from 1st February, and registered services (presumably!) from 1st January.

Forum Moderator   | Let us know if you have any issues

Service Manager, Coatham Connect

tyresmoke
30 Dec 2019, 6:34 pm #206

(30 Dec 2019, 5:55 pm)streetdeckfan But then we have to ask why is it, after all these years, they've only in the past few months realised they had to comply?
Was it a case of them hoping that if they didn't say anything, nobody would realise that the regulations weren't specific enough to include that type of work?
Or was it a case of them genuinely not realising that they had to comply because in the past they were excluded?

But like I said above, at the end of the day that shouldn't matter. People don't stop needing accessible buses just because it's paid for by a school or parents

I think it was a case of literally assuming only registered services would be encompassed by the regulations, and as nobody had said otherwise until a few months ago then everyone thought that was the case. I read it differently in that all fare paying services would be included, but there we go. I didn't expect fares paid off-bus would be included, eg private schools & rail replacement.
In the last hour there's been an announcement that PSVAR has been delayed until 31st July, to cover the rest of 2019/20 school year, for home to school services only. Rail replacement will still have to comply from 1st February, and registered services (presumably!) from 1st January.


Forum Moderator   | Let us know if you have any issues

Service Manager, Coatham Connect

30 Dec 2019, 6:54 pm #207
(30 Dec 2019, 6:34 pm)tyresmoke I think it was a case of literally assuming only registered services would be encompassed by the regulations, and as nobody had said otherwise until a few months ago then everyone thought that was the case. I read it differently in that all fare paying services would be included, but there we go. I didn't expect fares paid off-bus would be included, eg private schools & rail replacement.
In the last hour there's been an announcement that PSVAR has been delayed until 31st July, to cover the rest of 2019/20 school year, for home to school services only. Rail replacement will still have to comply from 1st February, and registered services (presumably!) from 1st January.

This isn't meant to be dig at you personally, but I don't see how you can think all fare paying services would be included, but not fares paid off-bus.
At the end of the day, money is changing hands for that service to be run, it doesn't matter when or where that money was paid, or who paid it. 

This is the issue with the way our government/legal system works. They prefer to leave things up to interpretation rather than setting things in stone, which in some cases is very helpful as not every situation is the same, but in this case has caused a plethora of issues
streetdeckfan
30 Dec 2019, 6:54 pm #207

(30 Dec 2019, 6:34 pm)tyresmoke I think it was a case of literally assuming only registered services would be encompassed by the regulations, and as nobody had said otherwise until a few months ago then everyone thought that was the case. I read it differently in that all fare paying services would be included, but there we go. I didn't expect fares paid off-bus would be included, eg private schools & rail replacement.
In the last hour there's been an announcement that PSVAR has been delayed until 31st July, to cover the rest of 2019/20 school year, for home to school services only. Rail replacement will still have to comply from 1st February, and registered services (presumably!) from 1st January.

This isn't meant to be dig at you personally, but I don't see how you can think all fare paying services would be included, but not fares paid off-bus.
At the end of the day, money is changing hands for that service to be run, it doesn't matter when or where that money was paid, or who paid it. 

This is the issue with the way our government/legal system works. They prefer to leave things up to interpretation rather than setting things in stone, which in some cases is very helpful as not every situation is the same, but in this case has caused a plethora of issues

Adrian



9,566
01 Jan 2020, 3:22 pm #208
(30 Dec 2019, 6:54 pm)streetdeckfan This isn't meant to be dig at you personally, but I don't see how you can think all fare paying services would be included, but not fares paid off-bus.
At the end of the day, money is changing hands for that service to be run, it doesn't matter when or where that money was paid, or who paid it. 

This is the issue with the way our government/legal system works. They prefer to leave things up to interpretation rather than setting things in stone, which in some cases is very helpful as not every situation is the same, but in this case has caused a plethora of issues

It could be cast in bronze never mind set in stone, and you'd still get someone trying to find a loophole in it. The DfT guidance could have been clearer from the start, but there has still been a lot of trying to find that loophole. The regulations would have had to come in at some point. It could have been 2030 and you'd still have people unhappy with it, that they're not ready, etc.

Some coach operators invest massively in their fleets, but still won't be able to operate the full demands of the school contracts they have. Others invest very little and won't be able to at all. In my opinion, a lot of this has been down to the way Public Sector procurement works, and that it is based on the most economically advantageous tender. I haven't seen many (if any!) local authorities making wheelchair accessible vehicles a requirement in their schools contracts. There's also the short (single academic year) length of contracts that some local authorities are using, which doesn't give a business any security to invest in their fleet. Especially if such a high percentage of their business is this type of work. Ultimately it has created a race for the bottom; a low frills service for bottom dollar. 

I'm pleased a short extension has been agreed, to avoid us nose-diving off a cliff. There needs to be some sensible discussions now, including around tendering, so that these important school services can continue.

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Adrian
01 Jan 2020, 3:22 pm #208

(30 Dec 2019, 6:54 pm)streetdeckfan This isn't meant to be dig at you personally, but I don't see how you can think all fare paying services would be included, but not fares paid off-bus.
At the end of the day, money is changing hands for that service to be run, it doesn't matter when or where that money was paid, or who paid it. 

This is the issue with the way our government/legal system works. They prefer to leave things up to interpretation rather than setting things in stone, which in some cases is very helpful as not every situation is the same, but in this case has caused a plethora of issues

It could be cast in bronze never mind set in stone, and you'd still get someone trying to find a loophole in it. The DfT guidance could have been clearer from the start, but there has still been a lot of trying to find that loophole. The regulations would have had to come in at some point. It could have been 2030 and you'd still have people unhappy with it, that they're not ready, etc.

Some coach operators invest massively in their fleets, but still won't be able to operate the full demands of the school contracts they have. Others invest very little and won't be able to at all. In my opinion, a lot of this has been down to the way Public Sector procurement works, and that it is based on the most economically advantageous tender. I haven't seen many (if any!) local authorities making wheelchair accessible vehicles a requirement in their schools contracts. There's also the short (single academic year) length of contracts that some local authorities are using, which doesn't give a business any security to invest in their fleet. Especially if such a high percentage of their business is this type of work. Ultimately it has created a race for the bottom; a low frills service for bottom dollar. 

I'm pleased a short extension has been agreed, to avoid us nose-diving off a cliff. There needs to be some sensible discussions now, including around tendering, so that these important school services can continue.


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01 Jan 2020, 7:09 pm #209
(01 Jan 2020, 3:22 pm)Adrian It could be cast in bronze never mind set in stone, and you'd still get someone trying to find a loophole in it. The DfT guidance could have been clearer from the start, but there has still been a lot of trying to find that loophole. The regulations would have had to come in at some point. It could have been 2030 and you'd still have people unhappy with it, that they're not ready, etc.

Some coach operators invest massively in their fleets, but still won't be able to operate the full demands of the school contracts they have. Others invest very little and won't be able to at all. In my opinion, a lot of this has been down to the way Public Sector procurement works, and that it is based on the most economically advantageous tender. I haven't seen many (if any!) local authorities making wheelchair accessible vehicles a requirement in their schools contracts. There's also the short (single academic year) length of contracts that some local authorities are using, which doesn't give a business any security to invest in their fleet. Especially if such a high percentage of their business is this type of work. Ultimately it has created a race for the bottom; a low frills service for bottom dollar. 

I'm pleased a short extension has been agreed, to avoid us nose-diving off a cliff. There needs to be some sensible discussions now, including around tendering, so that these important school services can continue.

Like you say, it's become a race to the bottom. Which, I can understand as school budgets are tight.
And I can see why they may think there is a reason for not having the regulations apply.
For instance if there are no children at a school in a wheelchair, why would they need to spend extra acquiring a bus that can handle a wheelchair? (the answer obviously being what if someone has an accident half way through the school year)
streetdeckfan
01 Jan 2020, 7:09 pm #209

(01 Jan 2020, 3:22 pm)Adrian It could be cast in bronze never mind set in stone, and you'd still get someone trying to find a loophole in it. The DfT guidance could have been clearer from the start, but there has still been a lot of trying to find that loophole. The regulations would have had to come in at some point. It could have been 2030 and you'd still have people unhappy with it, that they're not ready, etc.

Some coach operators invest massively in their fleets, but still won't be able to operate the full demands of the school contracts they have. Others invest very little and won't be able to at all. In my opinion, a lot of this has been down to the way Public Sector procurement works, and that it is based on the most economically advantageous tender. I haven't seen many (if any!) local authorities making wheelchair accessible vehicles a requirement in their schools contracts. There's also the short (single academic year) length of contracts that some local authorities are using, which doesn't give a business any security to invest in their fleet. Especially if such a high percentage of their business is this type of work. Ultimately it has created a race for the bottom; a low frills service for bottom dollar. 

I'm pleased a short extension has been agreed, to avoid us nose-diving off a cliff. There needs to be some sensible discussions now, including around tendering, so that these important school services can continue.

Like you say, it's become a race to the bottom. Which, I can understand as school budgets are tight.
And I can see why they may think there is a reason for not having the regulations apply.
For instance if there are no children at a school in a wheelchair, why would they need to spend extra acquiring a bus that can handle a wheelchair? (the answer obviously being what if someone has an accident half way through the school year)

Chris 1



238
02 Jan 2020, 1:01 pm #210
(30 Dec 2019, 5:31 pm)tyresmoke Problem there is a lot of school services these days are not local authority backed - they're private contracts with the schools (or indeed parents) themselves. Majority of local authority contracted school buses will not have to comply as they're used only by kids with passes. Of course the schools etc didn't know anything about PSVAR coming in until local authorities told them a few months ago. Now it's all a bit of a rush to comply - the price of old Levante's has gone through the roof!

Whilst at the same time, presumably, the prices of non PSVAR vehicles have gone through the floor...
Chris 1
02 Jan 2020, 1:01 pm #210

(30 Dec 2019, 5:31 pm)tyresmoke Problem there is a lot of school services these days are not local authority backed - they're private contracts with the schools (or indeed parents) themselves. Majority of local authority contracted school buses will not have to comply as they're used only by kids with passes. Of course the schools etc didn't know anything about PSVAR coming in until local authorities told them a few months ago. Now it's all a bit of a rush to comply - the price of old Levante's has gone through the roof!

Whilst at the same time, presumably, the prices of non PSVAR vehicles have gone through the floor...

tyresmoke



5,300
04 Aug 2020, 11:33 am #211
Probably worth mentioning that the deadline for having PSVAR compliant vehicles on school services has been extended by another year to 31 July 2021 to take account of the fact that Covid has pretty much killed any chance of investment in fleets this year.
Personally I think a year is probably as far as they can realistically take it and therefore I don't see any further extension beyond this.

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Service Manager, Coatham Connect

tyresmoke
04 Aug 2020, 11:33 am #211

Probably worth mentioning that the deadline for having PSVAR compliant vehicles on school services has been extended by another year to 31 July 2021 to take account of the fact that Covid has pretty much killed any chance of investment in fleets this year.
Personally I think a year is probably as far as they can realistically take it and therefore I don't see any further extension beyond this.


Forum Moderator   | Let us know if you have any issues

Service Manager, Coatham Connect

Andreos1



14,155
09 Nov 2020, 10:15 am #212
https://www.bbc.co.uk/news/extra/8rvpt6b...nation-act

An interesting read, where I learned a lot. 
Some fantastic photos and footage too.

'Illegitimis non carborundum'
Andreos1
09 Nov 2020, 10:15 am #212

https://www.bbc.co.uk/news/extra/8rvpt6b...nation-act

An interesting read, where I learned a lot. 
Some fantastic photos and footage too.


'Illegitimis non carborundum'

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