BODS & PSV (Accessibility Information) Regulations 2023 – The unintended consequences on the Coach Industry

A challenge for many of us working in transport is keeping track of legislation. For example, the deregulation and the subsequent opportunities for reregulation of the bus network, has introduced new Acts of Parliament and repealed many aspects of earlier Acts, making it, at times, quite difficult for the layperson and, I suspect, the professional to follow.

Therefore, increasingly within the coach industry, I believed we are faced with the issue of unintended consequences. Changes to Acts and Regulations which have an impact on certain operations, which I suspect they were not really meant to do, but at the time these pieces of legislation were being drafted, they were not directly considered.

Take BODS (Bus Open Data Service) for example. I completely understand why having detailed information about the operation and performance of bus services is important and the benefit it brings to the customer and stakeholders. However, its application to certain categories of Home to School (H2S) transport which are not available to the public, and only need to be registered if certain criteria apply, was not something, I believe was actively thought about or understood at the time the regulation for BOBS implementation was drafted.

In fact, it is clear now that registration for H2S routes is quite inconsistent depending on the type of service that is being provided; who is responsible for providing the service (especially if it is a third party who is not the school or the coach operator); and how the fares are charged and collected.

Coach operators are taking different approaches. Some are accepting it is something that they need to do, even if they disagree with it and getting on with the job. A few others are ‘burying’ it and hope it goes away (not a good idea), and there are some, who are now deciding it is time to quit those school contracts that need to be registered and do something else with their vehicles. An unintended consequence with these regulations could lead to some schools unable to cover all their H2S requirements in the future!

Another more recent example, are the PSV (Accessibility Information) Regulations 2023, which although are excluded from ‘closed door’ H2S routes, are required for Rail Replacement (RR) services. For many coach operators, who may only operate RR services on occasions, they will have to purchase some relatively expensive equipment, learn how to programme it and spend time before a job putting in all the various combinations of journeys that might be required (especially if it is a complex RR operation with many variations).

Sadly again, one of the unintended consequences of this will be that some operators will cease to provide coaches for these events. I am already aware of train operating companies who are unable to provide RR services on occasions as there is no bus or coach operator available to cover the workings.

I have more sympathy with this example, as I can see the benefit to customers who use rail replacement services, having the confidence of knowing they are on the right route and getting off at the right stop, especially on a dark winters evening or in an unfamiliar area. But I just don’t think that the practical implications for the smaller coach operators have been thought through.

As ever the UKCOA (and I am sure other trade bodies) will continue to engage with the DfT and others to find a solution that works for all.

Peter Bradley
Managing Director
UK Coach Operators Association

Windsor – Coach Park link to town centre reopens

Refurbishment of the footbridge in Windsor which links the coach park with the town centre is due to be completed shortly, allowing the bridge to reopen, provisionally on Tuesday 7 May.

The footbridge, which is considered by many to be the gateway into Windsor, has been shut since the start of the year to allow the extensive refurbishment to be undertaken. This has included the complete cleaning and repainting of the steel bridge structure, preventative maintenance and anti-corrosion works, installation of new bridge lighting, cleaning the Perspex canopy and applying a mirror film to the underside of the canopy.

The complexity of the project, largely due to the proximity of the walkway to the platform at Windsor and Eton Central Railway Station, required this lengthy closure.

Operators are reminded that the coach park, located in Alma Road, Windsor SL4 3HY has 74 spaces. Entry is allowed up to 1830 but exit is permitted at any time. Charges apply daily (including bank holidays) between 09:00 and 2100. Details of charges and applications for coach park permits can be found here: Advance booking for special events in the town is not available.

Peter Bradley, Managing Director of the UKCOA notes that The Royal Borough have expressed their appreciation of coach operators and passengers for their patience while the refurbishment of the bridge has been underway. Structures such as these do require refurbishment from time to time and we are grateful that the works were programmed to take place post-Christmas but before the busy summer period.

We Are Recruiting – Director of Operations

As part of our continued expansion, the UKCOA is looking to appoint an exceptional candidate to the exciting new role of Director of Operations.

This will be a key position within the Association, responsible for moving forward issues that most affect coach operators. These currently include accessibility, decarbonisation, school transport, drivers’ hours and recruitment. If you are self-motivated, enjoy problem solving, negotiation and achieving results, then this may be the role for you.

Usually working from home, the job could be full or part time and the salary would be commensurate with experience. You will need to have experience of and a passion for the coach industry across the UK.

The UKCOA is a trade association of Coach Operators, run by coach operators for the benefit of the coach industry and its clients. It is supported by a wide range of Industry Partners.

For more information, a job description and how to apply please email [email protected]

 Closing Date Friday 24 May 2024

Praed Street: Friday 3 – Monday 6 May 2024

Contractors working on behalf of Westminster County Council will be
carrying out resurfacing works causing a full road closure of Praed Street between Spring Street and Norfolk Place (including London Street).

21:00 Friday 3 May until 05:00 Monday 6 May 2024

Tour buses will need to divert but should still be able to access the tour stop at South Wharf Road from Sussex Gardens via Norfolk Place.

Please note: Westbourne Terrace (Bishops Bridge Road to Sussex Gardens) must not be used as a diversion.


PSVAR: Next Levels of Compliance – 1 August 2024

There are just over 3 months to go before the next step in the minimum levels of compliance required for those who have a ‘Special Authorisation’ for vehicles used on Home to School (HTS) and Rail Replacement (RR) services.

From 1 August 2024, the following levels of compliance will be required:

  • Band A – For fleet sizes between 1 and 5 vehicles – At least 50% of the fleet partially compliant;
  • Band B – For fleet sizes between 6 and 9 vehicles – At least one fully compliant vehicle and at least 50% of the rest of the fleet partially compliant;
  • Band C – For fleet sizes between 10 and 29 vehicles – At least 15% of the fleet fully compliant and at least 50% of the rest of the fleet partially compliant;
  • Band D – For fleet sizes of 30 vehicles or more – At least 25% of the fleet fully compliant and at least 50% of the rest of the fleet partially compliant;

The ‘fleet’ is just those vehicles that are used on HTS and RR duties; vehicles that are never used on this work (or are used on HTS services that do not carry any paying passengers) can be excluded from the fleet totals.

Partial compliance requires vehicles to comply with parts of PSVAR schedule 3 as follows:

  • paragraph 2 (floors and gangways)
  • paragraph 3 (seats)
  • paragraph 4 (steps, excluding sub-paragraphs 1d, 1e, 1f, and 5)
  • paragraph 5 (handrails)

i.e.: it does NOT include any requirement for a wheelchair lift or destination equipment.

If, since you applied for your exemption from PSVAR, your fleet used to provide HTS or RR services has changed (either increased or decreased) which has moved you into a different ‘band’, you must notify the Department for Transport (DfT) at [email protected].

These are important changes; for coach operators who are Band B or C it requires you to have fully compliant PSVAR coaches for the first time, and for Band D there is a significant uplift in the number of coaches that need to be fully compliant. If you don’t already have plans to meet these requirements by 1 August, we suggest you make this a priority in the immediate future, as the demand for fully compliant PSVAR vehicles is likely to be high over the next few months.

Victoria Street and Buckingham Palace Road: Tuesday 2 – Tuesday 16 April 2024

From 05:00 on Tuesday 2 April until 21:00 Tuesday 16 April 2024 roadworks will be taking place at the junction of Buckingham Palace Road and Victoria Street.

The impacts are as follows:

  • Buckingham Palace Road bus stop P and coach stop 16 also closed. Operators normally using coach stop 16 should use stops R or Z5 as an alternative throughout the works.
  • Only one lane open on Buckingham Palace Road through the Victoria Street junction, offside lane three.
  • Only one lane open on Victoria Street, nearside lane one.

Please note: On Buckingham Palace Road, as Victoria Street is crossed, there is a tight manoeuvre required in order to re-join Buckingham Palace Road southbound and avoid the contra-flow bus lane (see worksite plan below). Coaches (and HGVs) have passed this location without issue.

Operators therefore have two options:

  • Remain on line of route via Buckingham Palace Road but ensure drivers take extreme care when negotiating the area around the worksite (if in doubt drivers should turn right on to Grosvenor Gardens and head back around the one way system and join the diversion below).
  • Divert via Bressenden Place and Victoria Street before re-joining Buckingham Palace Road southbound – see below.