Peter Bradley urges operator involvement in the ongoing review of PSVAR and incremental steps to improve accessibility
It was on Wednesday 13 April last year, just a few days before Easter, that the email arrived from the Department for Transport (DfT) announcing the launch of medium-term exemptions (MTEs) from PSVAR for rail replacement (RR) and home-to-school (H2S) services. I remember it well; I was in bed with COVID-19, but it was important enough to email our members that same evening.
It gave us, in effect, a four-year exemption plus an incremental plan to improve accessibility of the RR and H2S fleets. It introduced the concept of PSVAR partial compliance, something that we as a trade body had worked closely with DfT in developing. It also, as I mentioned last month in the review of the year, tried to provide a balance with those operators who had got themselves ready in time for the original deadline at the beginning of 2020. The first milestone in these new exemptions was August 2023 which, back then, seemed a long time away.
The MTEs introduced four separate categories for operators as follows:
- Band A: One to five vehicles
- Band B: Six to nine vehicles
- Band C: 10 to 29 vehicles
- Band D: Over 30 vehicles.
The vehicle fleet size solely relates to those vehicles used on RR and H2S, not the operator’s entire fleet.
The MTEs also introduced the categories of ‘fully compliant’ and ‘partially compliant’. Fully compliant refers to a vehicle that complies with all paragraphs of the following parts of PSVAR:
- Schedule 1: Concerning facilities for wheelchair users
- Schedule 3: Concerning other accessibility features.
Partially compliant refers to a vehicle that is not fully compliant, but as a minimum complies with the following parts of PSVAR schedule 3 (ie: It does not include any requirement for a wheelchair lift or destination equipment):
- Paragraph 2 (floors and gangways)
- Paragraph 3 (seats)
- Paragraph 4 (steps, excluding sub-paragraphs 1d, 1e, 1f, and 5)
- Paragraph 5 (handrails).
These steps commence on 1 August. From that date all operators (bands A to D) must ensure that, of the fleet of coaches that are allocated for use on RR or H2S, 25% meet the PSVAR partially compliant category.
In addition, for operators in band D, 15% must be fully compliant with PSVAR.
The majority of operators should find partial compliance relatively easy, as most coaches manufactured since 2008 (and some before that date) meet the requirements. Nevertheless, I would strongly recommend checking with the manufacturer of the vehicle that it does comply with the partially compliant category and, more specifically, that the handrails meet the ‘colour contrasting’ category requirements – don’t get caught out on a technicality.
Further incremental steps are applied on 1 August 2024 and 2025. However, the sting in the tail is: “These exemptions will expire on 31 July 2026. From 1 August 2026, operators will be expected to comply with PSVAR in full, subject to any changes which may be implemented as a result of the upcoming review of PSVAR” (gov.uk).
The review is underway and I understand we will be hearing from DfT soon. UKCOA, and I am sure other trade bodies, will be fully involved in the review. However, please participate when asked to do so and join a trade body if you are not already a member of one. This is too important to ignore.