Transport CommitteeWritten evidence from Campaign for Rail (DAT 34)

Introduction

1. The Campaign for Rail is an organisation that advocates railway interests and the best interests of all rail passengers and groups, including (but not limited to) Rail User Groups, Freight Development, and re-opening of lines and services. We also lobby for and promote rail interests with the relevant statutory bodies. Our organisation has been in existence for a year, and this our first submission to your select committee.

2. We are pleased that your select committee has launched an inquiry into the accessibility of public transport by disabled persons. There is no doubt that accessibility to the railways for passengers with disabilities has improved substantially over the last 30 years. The days when passengers in wheelchairs were hidden in guards vans, where railway staff did not recognise disability and rarely offered assistance, and where new infrastructure was provided that was difficult for disabled passengers to use have thankfully long gone. However, matters are still not altogether satisfactory. While the rail industry has made great strides, there are a number of issues that need to be tackled, and with the growing amount of legislation regarding disability there needs to be swift progress.

Defining Disability

3. There are over 10 million disabled people in the UK,1 of which 6.9 million are of working age, representing 19% of the working population.2 Disability covers a wide range of conditions, such as mobility difficulties, multiple sclerosis, blindness, hearing impairments, learning disabilities and speech impediments, which affect a person’s quality of life. Many disabled people will not be covered in statistics as they have not formally registered as “disabled” owing to a perceived stigma, even though doing so opens up schemes such as the Disabled Persons Railcard.

4. People can also experience “temporary disability”. A slip or fall leading to an ankle injury, for example, may restrict someones mobility and their ability to get around.

Independence v Assistance

5. More and more people with disabilities want independence. The railways have traditionally been geared up to offer “assisted travel”, ie help from railway staff such as station assistants and conductors in order to complete journeys. BR and the privatised rail companies over the years have encouraged disabled passengers to book this assistance in advance by ringing a dedicated helpline, or by alerting the operator that they will need assistance when booking tickets on-line (the company London Midland for example offers this service to customers).3 However, many passengers will prefer to travel without assistance, valuing their independence. The industry has got to adapt to this societal change, provide help when requested, and be easily accessible for all. People with disabilities are not expected to ring the supermarket in advance if they need assistance with their shopping. Why should they always be expected to book assistance when travelling by train?

At the Station

6. The rail industry, together with central government and local transport authorities such as Centro have made great improvements in terms of improving the accessibility of stations for those with mobility impairments, by adapting stations to meet modern needs, increasing the number with step free access, and providing ramps or lifts. There are many passengers who can walk a limited distance to access public transport providing they do not need to climb, or descend, stairs. However, there are still too many stations which are inaccessible and this provides something of a quandary for the rail industry and funding authorities. A classic example in the West Midlands in Tyseley station. The station was built by the GWR in the Edwardian Era, and access to the platforms is still via two flights of steps, inaccessible to a passenger in a wheelchair and difficult for a passenger on crutches to access. Lifts here would help, but the station is a listed building, the cost of the facilities would run into hundreds of thousands of pounds, would require adaptation of the building and a platform extension and probably temporary closure of the station. In order for the rail industry to meet the requirements of the Equalities Act 2010 and its tests of “reasonableness” stations like Tyseley will surely need adaptation; otherwise the railway will not comply with the law.

7. Smethwick Galton Bridge is a modern station, built in the mid 1990’s when the line from Birmingham Snow Hill to Smethwick was re-opened and has been built with the DDA in mind. The station is an “interchange”, providing connections for rail routes serving the Midlands and the North West. There are lifts between platforms and the station concourse providing step free access. However, when the station is unstaffed, a situation that has become increasingly common following the staffing problems affecting London Midland, the lifts are locked “out of use”. This presents difficulties even where a passenger has requested assistance—if a passenger in a wheelchair wishes to travel from Liverpool to Kidderminster, changing at Galton Bridge and needing assistance at Galton Bridge, if the station is unstaffed and the lifts are out of use they are either a) stranded at Galton Bridge until a rail employee comes to assist or b) forced to go to Birmingham and change trains there—and the simple connection using a lift ends up being a 10 minute trip between Birmingham New Street and Birmingham Moor Street stations through a busy city centre. There have also been examples of stations with lifts where they have been working properly in the morning, but at which passengers have arrived back in the evening to find that they have been locked out of use. (Burton-on-Trent and Tamworth are two notable examples we are aware of).

8. Some stations have had money to improve accessibility for the disabled via the Department for Transport “Access for All” money, however this funding pot is limited given the amount of work that will need to be done and the varying condition of station buildings, some of which are modern, some built during the rail modernisation of the 1950’s and 1960’s, others built in the Victorian rail age which will require extensive work. Kidderminster, a station rebuilt by BR in the mid 1960’s received £2.5 million through the scheme in 20074 to provide a new footbridge and two lifts, to provide an alternative to stepped access and a steep incline to Comberton Hill. The facility is an excellent one. However, despite the works it is often locked out of use—which is not acceptable given the public funding provided.

9. There has been a tendency to move away from the standard designs of signage at stations (developed by BR in the corporate identity scheme of the 1960’s) towards bespoke designs brought in when franchises change. BR’s signage, using black Helvetica bold typeface on a white background was clear, easily readable and simple to understand. Whilst some companies have replaced their BR style signage with different designs which are an improvement others have provided signage which is poor and must be difficult for a partially sighted passenger to read. The signage provided by Network Rail at main stations is particularly poor in this regard—often using information in small text. The practice of companies changing all the signage at stations at a franchise change to impose their “brand” at a franchise change is wasteful and it would be better for the industry to agree a standard font and set of pictograms for station nameboards and directional signage to minimise costs.

10. For passengers with visual impairments audio announcements are often vital at busy stations, so they get the information needed about when their train is due to depart, which platform to use, and also if there are any delays or problems. However, there has been a tendency at some busy stations to reduce the amount of audio announcements. This poses problems for passengers who are partially sighted and means they often get information later than fully sighted rail users. (It is reckoned the number of people in the UK with sight loss will double to four million by 2050).5 It is also disappointing that the industry, when completing refurbishment schemes, have failed to upgrade and improve the public address system provided at stations. Birmingham Moor Street station is a case in point, the station has had significant investment and is the second busiest in Birmingham City Centre, and provides a pleasant atmosphere in which to wait for a train. However, there is no audio announcement system informing passengers of their trains. There are regular announcements played over the tannoy regarding security and keeping hold of your belongings, but very few regarding the running of the service which is much more useful to all passengers. Indeed, even when there is significant disruption at this station very little use is made of the manually operated PA equipment.

11. The decision to make more and more stations unstaffed also means more and more passengers with disabilities will be faced with using ticket machines. They are not always well designed and the modern machines, while being able to sell a wider ranger of tickets compared to those provided by British Rail, are not always user friendly. It is very easy for a passenger to end up buying a ticket that is not the correct one for the journey they wish to make or which is more expensive. The Disabled Persons Protection Policy of London Midland states:

“If you are unable to buy a ticket before travelling, due to not being able to access the Ticket Office or Ticket Vending Machine, you will be able to buy a ticket on the train, or at your destination, without penalty.”

It is unclear from the document though how the company would apply the policy. If faced with a passenger suffering a severe learning difficultly travelling from an unstaffed station but with a machine, would a Revenue Protection Inspector automatically issue a penalty fare, on the grounds that a machine was available (but one that the passenger may have had considerable difficultly using), or would they allow a normal ticket to be bought on train or at the destination station (which may be operated by an entirely different company)? Surely there should be a consistent approach which supports passengers with learning disabilities and which does not criminalise them?

12. Whilst the current policy of not staffing lightly used stations is understandable, the policy is not symmetrical. We suggest that there should also be a lower footfall limit (perhaps 100,000 p.a.) above which a staff presence must be provided. Many stations are already staffed for a single morning shift and extending this practice this will make a huge improvement to the travel information available to passengers, improve the service offered to passengers who require assistance to make their journeys and doubtless also improve revenue collection.

13. Passengers with disabilities should also have access to blue badge spaces at stations with car parks, and ideally they should be as near to the platform or booking office as possible. It is important though that these spaces are not abused; there have been many stories over the years of people either parking in blue badge spaces they were not entitled to use without the badges, or fraudulently using them (such as a case in Birmingham where staff from a bank were using badges given to their relatives to enable them to park in blue badge spaces near the office). It is important that these spaces are monitored, and any deliberate abuse of the blue badge scheme referred to both the British Transport Police and the issuing authority of the badge to enable an investigation to take place and potential prosecution and/or withdrawal of the badge.

On the Train

14. Most trains introduced since the mid 1990’s have been provided with the Disability Discrimination Act in mind and feature spaces for wheelchairs, toilets accessible to the disabled and improved signage featuring Braille. Electronic information displays showing the trains calling points and other useful information are now provided, and automated audio announcements are now standard on many modern fleets.

15. However, there is of course a significant amount of rolling stock on the rail network inherited by the privatised TOC’s from British Rail that was commissioned in the pre DDA days. The oldest of these trains date from the mid 1970’s (class 313, 314, 315, 508 and Mark 3 carriages) with the newest dating from the immediate pre-privatisation period (Mk 4 carriages, class 323, 465, 466 and 365 electric units and class 153, 165, 166 and 158 diesel units). It is likely that many of these will be in service for some time with the newest BR vehicles likely to be in service for a further 10–15 years minimum.

16. The industry faces a significant challenge in the next few years, one that may be bigger than that faced when the decision was taken to replace the slam-door stock on the routes in the South and South East of England. The UK has adopted a European Standard, the Technical Specification for Interoperability for Persons with Reduced Mobility (PRM TSI). There is a 1 January 2020 deadline for rail vehicles running on the network to comply with this standard.

17. It is clear that it would be uneconomic, and indeed undesirable, for certain fleets of trains to be refurbished to this standard and hopefully this piece of legislation will allow the dreadful cheap and nasty “Pacer” Units introduced in the 1980’s by BR to be replaced and sent on a one way trip to the scrapyard. However, large numbers of vehicles will need to be overhauled to comply with PRM TSI over the next seven years. At the same time availability will need to maintained, a growing railway with more passengers using it than ever before means the time stock is kept in works will need to be kept to a minimum.

18. Chiltern Railways last year introduced rakes of re-furbished Mark 3 coaches onto its services between London Marylebone, Birmingham and Kidderminster. Of note are these trains, originally introduced by British Rail in the 1970’s and 80’s have been overhauled to PRM TSI standards, with the centrally locked slam doors being replaced by power sliding plug doors. This project shows what can be done on more elderly trains and it is felt the work done to the Mark 3’s would allow them to remain in service for 20 years.6 Meanwhile Greater Anglia and Porterbook have recently begun a programme to refurbish their class 156 trains, introduced in the mid 1980’s, to PRM TSI standard. Some newer vehicles need less work. Others, such as the class 323 units will need extensive works (particularly to replace the current toilet with a disabled one) and in some cases it may be necessary to apply derogations.

19. In our view the Department for Transport, the rolling stock leasing companies and the train operators need to work up a strategy for upgrading the inherited BR stock that is likely to be required beyond 2020 to PRM TSI standard, whilst enabling the stock that will not be refurbished to be replaced by January 2020. This planning needs to commence now to ensure stock is overhauled quickly, works capacity is managed and there is sufficient stock to ensure the timetable continues to operate, while ensuring accessible rolling stock is available for 2020 and beyond.

January 2013

1 Family Resources Survey (FRS) Disability prevalence estimates 2007–08

2 Disability Rights Commission, July 2008

3 http://www.londonmidland.com/p/accessibility/

4 6 Apr 2010, Hansard, :Column 292WH

5 Source: Access Economics, 2009.

6 http://www.railtechnologymagazine.com/Rail-Industry-Focus-/refurbishing-the-mk-iiis

Prepared 13th September 2013