UKCOA tables proposals in reply to PSVAR call for evidence

The UK Coach Operators Association (UKCOA) convened an online members’ meeting on 16 August, inviting members of the coach industry to deliberate on UKCOA’s reply to the Department for Transport’s (DfT’s) call for evidence on PSVAR.

A redesign of side lifts, balancing expectations with zero-emissions development, and a new approach to the concept of accessibility, form key parts of the Association’s reply.

Chaired by UKCOA President and head of the trade body’s PSVAR Working Group, Stephen Telling, the meeting aimed to ensure the industry’s voice is cohesively represented in UKCOA’s official response to the government.

It comes after UKCOA’s proposed reply to the call for evidence was distributed earlier in August, with an agreement to submit that reply by 31 August ahead of the September deadline.

In a candid opening commentary, Mr Telling expressed reservations about the scope of the existing PSVAR framework. Highlighting a gap, he remarks: “PSVAR, as it stands today, predominantly caters to wheelchair users. There are 10 million disabled people in some other form, and who could benefit from having a better lift and better facilities on coaches. That is part of our work going forward.”

Mr Telling also questioned the expectations placed on coach operators for 100% compliance with the Regulations, drawing parallels with other industries such as the hotel trade, where such uniformity is not required.

UKCOA has presented a comprehensive set of proposals in its reply. These are:

1. Partial compliance: All new coaches, from a specified time, should adhere to PSVAR’s partial compliance standards, excluding wheelchair lifts and destination equipment. Mr Telling notes that coaches built since 2006 largely meet this standard.
2. Pre-installation readiness: Future coaches should be designed with the capability to incorporate destination equipment and a new style lift if required, although it doesn’t necessarily need to be fitted immediately.
3. Redesigning side lifts: The existing side lifts, which cater primarily to wheelchairs, have been found wanting in functionality by many UKCOA members. The Association proposes the design of a new lift system to accommodate both wheelchairs and standing passengers without compromising on seating or luggage space. A working group including representatives from DfT, the Disabled Persons Transport Advisory Committee (DPTAC), vehicle manufacturers, and trade bodies is suggested, with UKCOA keen on being an active participant.
4. Infrastructure development: To enable the deployment of these new lift designs, UKCOA recommends the formation of another working group. This group would devise guidelines for establishments like local authorities, schools, tourist attractions, and motorway service stations. The Department for Transport and relevant trade bodies are expected to contribute, with the overarching goal of revising PSVAR standards.
5. Balancing PSVAR and zero-emission standards: Both PSVAR and zero-emission requirements should be addressed in tandem, ensuring luggage space and vehicle weight are minimally impacted. Mr Telling comments on the current challenges posed by battery-electric coaches and the nascent state of hydrogen-powered vehicles.
6. Guidelines for vehicles with PSVAR: The UKCOA proposes not to retract already-established legislation. For vehicles required to be fitted with PSVAR:
   1. Operators must ensure a fully specified PSVAR vehicle is available upon request
   2. Full PSVAR should not be mandated on coaches not used on scheduled services
   3. The current minimum compliance levels should remain in force until 1 August 2025
   4. From a specified time, new vehicles used on scheduled services, including home-to-school and rail replacement, should comply with full PSVAR standards, ideally with the new lift design.
7. Vehicles with fewer than 22 seats: UKCOA recommends developing specific PSVAR standards for such vehicles. Following a discussion with manufacturer Ilesbus, issues of practicality, especially regarding lift installations, were raised, with UKCOA Managing Director Peter Bradley cautioning against radical changes, particularly those retroactively applied to existing designs.

“The big thing here is trying to meet everyone’s needs and requirements,” says Mr Telling. “It’s going to be incredibly difficult, and the trouble is how we convince the powers that be at DfT. We’ve just got to put it into the best words that we can – there will be further meetings to expand on these points.”

Suggesting that the way forward for coach will be a “complete redevelopment” of the vehicle, he adds: “We need to be developing and looking forward. That’s part of what this paper is about – not about going backwards. We can’t afford it. My idea of a good deal is where we all win. We’ve delivered for the passengers, that’s why they travel with us – that’s what we need to develop going forward. That can’t be done day one, it’s going to take time. That’s what our paper has said. The one difference this time is that this is a coach operators’ association, for coach operators, and it is absolutely putting forward the coach operators’ side and ways we can remedy this for our own industry.”