The Department for Transport has issued an exemption for H2S services until the summer of 2021 by which time it is hoped a permanent solution will be agreed that will meet the needs of disabled passengers at a measured and appropriate level.
As of 1st January 2020, the final provisions for the Public Service Vehicle Accessibility Regulations (PSVAR) came into effect.
This means that all fee-charging shared vehicles introduced within the last 20 years, designed to carry more than 22 passengers and providing a local or scheduled service, must be accessible to all. However, despite the legislation now being fully in effect, many schools and transport providers have been taken by surprise by home-to-school services being identified as in-scope of the legislation, as it was previously thought that this was not the case.
For example, under PSVAR, scheduled bus services are in-scope because at any stop there could be a disabled passenger, however leisure trips are out of scope, presumably because the passengers are known in advance and an accessible vehicle will be procured if necessary. This should apply to home-to-school travel, where the same situation – namely, the passengers being known in advance – applies.
With this in mind, we’ve outlined a selection of the options available to schools in the wake of PSVAR, while also giving our thoughts on each option’s viability and whether additional action may be needed.
Stop offering home-to-school services
While there is an exemption period in effect for the legislation – until the beginning of the 2020/21 academic year for independent schools, and a minimum of two years for state schools – this is not enough time for the market to source new accessible vehicles to the level that the legislation requires. If schools cannot become fully-compliant, they may be forced to consider ceasing their home-to-school travel offering due to it no longer being financially or logistically viable.
This would have a catastrophic effect on both pupils and the schools that rely on home-to-school travel as a key part of their admission strategy, as well as a source of competitive advantage to attract pupils. A survey of parents from a school in Hertfordshire revealed one in two parents (50%) would not be able to send their children to that school if it stopped offering a home-to-school service.
Reduce all routes to smaller vehicles
Because vehicles of 22 seats or under are exempt from PSVAR, one option that has been suggested is using smaller vehicles across home-to-school routes to circumvent the legislation. However, this would directly fly in the face of one of the main benefits of shared school transport – namely, taking cars off the road and therefore both reducing emissions and crippling traffic congestion around the school. With less seats available per vehicle, more are naturally required to transport pupils.
This also creates further issues for schools in terms of parking; for example, a school in Buckinghamshire could fit 14 full-size coaches when parked in a custom-built coach park, but only 32 cars. This meant that, in order to accommodate parents driving their kids to and from school, 271 extra spaces would have been needed in the morning, and 240 in the afternoon, with the alternative to have parents drop their child off outside the school – creating additional sustainability and student safety risks.
Use buses instead of coaches
Another option that has been suggested to comply with PSVAR is to replace coaches with buses, which are technically compliant with the legislation.
Once again, this is a short-sighted option that does not take all of the necessary implications into account. For starters there is pupil safety to consider. By taking pupils off executive-grade coaches with 3-point seatbelts in favour of buses with 2-point seatbelts – or even no seatbelt at all, as is often the case – schools could directly compromise their pupils’ safety between home and school.
There is also the case that buses are not nearly as well-equipped to transport pupils as coaches. Buses are often far less comfortable, and do not have the required carrying capacity to transport the luggage many students require each day, such as sports bags or large musical instruments.
This essentially leaves children in a situation where they are taken off luxury coaches with 3-point seatbelts and put into under-equipped buses with no seatbelts and provision for standing passengers – technically achieving compliance, but greatly compromising pupil comfort and safety.
Source compliant vehicles
While retrofitting existing vehicle fleets seems to be the most simple solution, and what PSVAR intends to become the norm, this route is far more complicated than it appears on paper.
As it stands, many transport operators have no plans to add accessibility equipment to their vehicle fleets, as many operators’ coaches are used for leisure first and are therefore mostly unaffected by the legislation. If pressed, these operators are likely to take the option of simply withdrawing from the home-to-school transport market.
The above factors will greatly affect the supply of accessible vehicles for schools, which in turn significantly increases costs for schools working to increasingly-stretched budgets – that is, if enough accessible vehicles can be sourced to meet the needs of schools across the country in the first place, which is by no means guaranteed. An uneccesary increase in transport costs can only result in a decrease in funds available for the other areas of a school.
Should the legislation be changed?
While all schools naturally have the safety and wellbeing of their pupils firmly front of mind and are committed to supplying accessible services to those who need them, the current legislation simply does not allow for this to be achieved sustainably, no matter what option schools take.
We would argue that a far more viable application of PSVAR is adherence to a “right vehicle, right journey” policy that we have seen great success with in the past. This would mean requiring schools to simply provide accessible vehicles when they have passengers that actually need it, instead of the legislation being short-sightedly applied to all, as is the current situation.
At Kura, our industry-leading service is built on decades of transport expertise – particularly in the home-to-school sector – if you’re confused at all about how the legislation might apply to your school, get in touch and see how we can help!