Consultation outcome

Bus Services Act 2017 accessible information: consultation outcome

Updated 30 March 2023

Executive summary

The Bus Services Act 2017 amended the Equality Act 2010 to create sections 181a-181d which enable the introduction of Accessible Information Regulations (AIR). In doing so, Ministers recognised the omission of consistent accessible information onboard local services in Great Britain, and the negative impact of a lack of information on the ability of some passengers to travel confidently.

In Summer 2018, we consulted on proposals for introducing Accessible Information Regulations. We proposed that operators of local services in Great Britain should be required to provide on board information in audible and visible formats, identifying the respective route, each upcoming stop, and points at which diversions begin and end. The proposals attempted to balance benefits for passengers with operator flexibility, suggesting high level standards for information provided, whilst remaining agnostic as to the specific solutions that would be used. An implementation timetable and exemptions from the requirements were suggested, recognising that the industry is large and diverse, and that some operators would be better placed than others to respond swiftly to new requirements.

Over the course of the consultation period, we discussed our proposals with around 250 stakeholder event attendees, and received around 350 responses, including 229 submitted as part of a campaign organised by Guide Dogs.

Respondents were generally supportive of our overall approach of seeking to improve the availability of information provided on board local services. However, a wide variety of views were expressed regarding the technical aspects of the proposals. This included the categories of information that should be provided, the way its quality should be assessed, and timescales for the requirements to apply to smaller operators and older vehicles. Whilst a clear consensus was not evident for every question asked, the responses have enabled us to review and revise our proposal to strike a better balance between meeting the immediate information needs of passengers and implementing a new requirement which is sufficiently proportionate in its scope and application.

We will now move forward to finalise the Accessible Information Regulations, with a view to commencing the new legislation by October 2023. These regulations will support growth by providing key information for both disabled and non-disabled people when using local services so they can access employment, education, and leisure more easily.

Background

In 2000, the Public Service Vehicles Accessibility Regulations (PSVAR) were introduced under the Disability Discrimination Act 1995, aiming to ensure that bus services met the needs of all passengers wishing to use them, including those who were disabled. Today 99% of buses across Great Britain have an accessibility certificate, confirming that they meet the requirements of PSVAR or equivalent international vehicle standards. In practice this means that they incorporate at least one wheelchair space, a boarding ramp or lift, priority seating and other facilities to help disabled passengers to board, alight and travel in comfort and safety.

However, PSVAR didn’t require the provision of audible and visible information informing passengers of upcoming stops and the direction of travel. Campaigners for the rights of disabled people have argued that this omission puts such passengers at risk and reduces their confidence to travel. The survey ‘Road to Nowhere’ organised by Guide Dogs in 2012-13 found that 70% of blind and partially sighted respondents in the UK stated travelling by bus caused them difficulty in visiting places, and 81% stated that they felt unable to enjoy the freedom of travelling by bus compared to non-disabled passengers.

After the Bus Services Act 2017, which amended the Equality Act 2010 to enable us to introduce Accessible Information Regulations, we worked with a range of stakeholders to understand how accessible information was currently provided by those operators and authorities which had pioneered its provision, and what lessons could be learned for the eventual AIR. This enabled the development of a formal proposal, which was subject to public consultation during summer 2018. The proposed approach attempted to balance the creation of discernible benefits for passengers, with a requirement which was capable of being implemented by the industry and which minimised negative consequences for less profitable routes and smaller operators. It maintained a technology-neutral stance, recognising that operators were better placed than government to identify appropriate solutions for providing accessible information. It also reflected the advice of stakeholders in England, Scotland and Wales on the nature of services in all three nations.

Consultation activity

The Bus Services Act 2017: Accessible Information consultation was launched by the then Parliamentary Under Secretary of State, Nusrat Ghani MP, at Reading Buses on 5 July 2018. It ran for ten weeks until Sunday 16 September 2018. We promoted the consultation through mainstream and social media channels, and through direct contact with potential consultees.

Seven stakeholder events were organised during the consultation period in Great Britain. Write-ups from these events have been considered as part of the review of responses for this report. We engaged with over 250 people at these events. This provided an opportunity to explain the background to our proposals and explore technical aspects in depth.

Stakeholders responding to the consultation were asked to complete an online form. Additionally, several written responses were also received by email.

Summary of responses

We received 101 discrete responses to the questions in the consultation, of which 61 were via the online form and 40 by email. We also received an additional 6 responses by email which provided free text based on the proposals without answering the consultation questions themselves.

The majority of responses were received from passengers (28) and local authorities (24), partly reflecting attendance at the stakeholder events, which were shared with the Bus Open Data consultation. Additionally, responses were received from: both large and small bus and coach operators, including those representing them (18), from organisations representing disabled people (18), and those with an interest in transport generally (8), and the audible-visible market (5). 229 responses were provided as part of a campaign by the Guide Dogs for the Blind Association, emphasising the organisation’s strong support for the accessible information agenda and its wish for swift progress to be made in implementing it. Whilst the campaign responses have not been counted individually as part of the response summaries for each question, note has been taken of the strength of feeling they demonstrate.

Analysis methodology

The consultation document presented the case for change. For each of the key powers available, it proposed a preferred approach and invited responses on its suitability. We also published a consultation stage Impact Assessment alongside the consultation to describe the economic case for change. Versions of the consultation documents were made available in alternative accessible formats to those requesting them.

Many respondents provided detailed comments in addition to their responses to the multiple-choice questions. Whilst we have commented on the quantitative results as an indication of overall sentiment towards the proposal, we have also carried out detailed analysis of the qualitative responses to assess the viability of the original approach. To this end, written responses were grouped around core themes to each of the questions, allowing us to identify any trends and to highlight concerns or suggestions which could be lost.

In most cases, we have chosen to describe stakeholders in general terms, rather than to identify them. In the case of a small number of organisations which have a particular role in representing the interests of a given group, and with their permission, we have identified them.

Proposal

We proposed to make Accessible Information Regulations using powers at Sections 181A-181D of the Equality Act 2010 to require the provision of information, including that it must be provided in both audible and visible formats. We referred to the provision of this information required on board local services in Great Britain as the ‘core proposal’.

We also proposed that, of the categories of information which the Equality Act 2010 enabled government to prescribe, Regulations should require the provision of information identifying:

• the route on which the local service is travelling
• the direction of travel
• each upcoming stop
• points at which the service is diverted from or returned to its scheduled route

We highlighted that, whilst the Equality Act 2010 also provided a power to require information relating to connecting services, the technological means to meet such a requirement was insufficiently mature to be implemented on a wide scale and in all envisaged contexts. Therefore, we did not propose requiring such information. We also proposed that the regulations should not prevent an operator from choosing to provide additional information, so long as information required by the regulations is not compromised.

AIR01: Response summary

Do you agree that the core proposal is an appropriate response to the need for change identified in this document?

Total percentage (%) responses

• Yes: 76%

• No: 12%

• Don’t know or no response: 12%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	10	5
Passengers	38	4
Local authority	18	3
Other	11	0

AIR01: Response analysis

Passenger experience

More than three quarters of respondents for AIR01 indicated that the core proposal was an appropriate response to the need for change identified. Stakeholders representing the interests of operators were more split on this question than those representing passengers. Of those responding positively, nineteen respondents explicitly acknowledged that the core proposal would help remove barriers faced by disabled and older users. Nine respondents stated that the proposal had positive, far-reaching implications, arguing that as well as disabled people, it would benefit those not familiar with a route or area.

The Disabled Persons Transport Advisory Committee (DPTAC), statutory advisers to Ministers on the interests of disabled transport users, commented:

DPTAC has long seen the omission of audio visual announcement systems from PSVAR as a significant barrier limiting bus use by some disabled people. Most obviously this affects people with a visual impairment and campaigning on this issue has been led by Guide Dogs.. However, there are many other people with a range of impairments who will benefit from the greater certainty about the journey they are on and their proximity to their destination that announcement systems give passengers.

Several operators also accepted the proposal as a proportionate response to a genuine customer need, with one large operator stating:

We believe that the core proposal is an appropriate response, not only to assist those with visual or hearing difficulties but also any passenger who may be new to the bus route and area in question: it is believed the core proposal is a sound balance between passenger benefits and flexibility for operators in terms of the proposed implementation dates.

Several organisations representing the interests of disabled people stated explicitly that a legislative approach was preferable to a voluntary approach in meeting the needs of passengers.

Cost

Cost was a predominant concern amongst stakeholders, with sixteen respondents highlighting it as a problem in their answers. Nine stated that the proposal would create disproportionate costs for operators, and five suggested this could result in the withdrawal of services. The provision of loans or grants to ease cost burdens was also discussed.

The Confederation of Passenger Transport (CPT) commented:

Elements of the proposals are onerous and would be expensive with, we believe, a low benefit to cost ratio and potential implications for some services.

This was a view that was shared amongst other respondents, with operators and local transport authorities also expressing reservations about cost impacting the availability of services.

Implementation practicality

The practicality of implementing elements of the proposal was raised as a potential issue by operators and local transport authorities. Though it was acknowledged that the principle of the proposal was well-intentioned, the level of detail specified was a concern.

Communication

Responses relating to communication between drivers and passengers were limited. One respondent representing the interests of disabled passengers commented that training drivers in good customer service was essential for maintaining good staff morale, and would reduce the need for technological solutions, which could demoralise drivers and isolate them from their passengers.

AIR02: Response summary

Do you agree that the proposed list of required information is an appropriate use of the powers available?

Total percentage (%) responses

• Yes: 72%

• No: 21%

• Don’t know or no response: 7%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	8	8
Passengers	37	8
Local authority	18	5
Other	10	0

AIR02: Response analysis

At AIR02 we asked whether the proposed list of information which operators would be required to provide onboard their services represented an appropriate use of the powers available. Over two thirds of respondents agreed that this was the case, including half of those representing operators and over 80% of those representing passengers.

The question concerned the five types of information that we proposed to require the provision of, but comments received focused particularly on two of these types:

• thirteen respondents, spread across different stakeholder groups, agreed that providing information about connecting services would be problematic at this time

• eleven respondents, spread across different stakeholder groups, were concerned about the challenge of providing information on diversions

Connecting services

The potential for information on connecting services to contribute to information overload was a common concern, with several respondents agreeing that it should not be provided at this time. A number of respondents supported our contention that providing information on connecting services would, at this stage, be constraining to implement.

Diversions

The subject of diversions was more contentious. In our proposal, we proposed that information about diversions should identify a point immediately before a service begins a diversion from its scheduled route, and a point immediately before it resumes the route.

However, DPTAC advised that passengers needed more information than simply a notification that a diversion was beginning, in order to make informed decisions as to whether they should remain onboard or make alternative transport arrangements. A similar sentiment was expressed by an operator:

For planned diversions, information needs to be given as the passengers get on – not just at the stop before the diversion begins. The very existence of a diversion further along the route influences whether an individual even begins that journey or plans an alternative route. This preliminary announcement should also include information on where the bus will re-join the route, as without it, individuals won’t have sufficient information to know if they need to consider an alternative route.

Cost

Cost was a concern for several local authorities, with regard to the provision of diversion and other disruption information. A large local government body said:

Needing to provide additional service information and manage temporary service changes (planned and unplanned) will be impossible for some without major IT systems investment and support for operational costs.

Stopping places

Though the majority of respondents agreed with the proposal’s specifications on stopping places, there were several comments on the importance of having up-to-date information on the National Public Transport Access Node (NaPTAN) database, as this would provide clarity and consistency in naming bus stops.

Terminating stops

DPTAC raised the importance of audible and visible information provision on the terminating stop, explaining that there is a risk that a passenger may unintentionally start on the return journey. DPTAC also advised that this information should be provided when the bus terminates in a location which wasn’t scheduled, for example if the vehicle breaks down, to enable passengers to interact with the driver about the location and options, and then make informed journey decisions.

Standards of accessible information

There were concerns about the level of flexibility given to operators as to how accessible information is provided. Some respondents noted that it would be beneficial to have a set of cross-industry requirements specifying how accessible information should be displayed. Uniformity across operators for font and text size, colour contrast, and volume were given as examples. A response to this specific point can be found under the response to AIR04.

AIR01 and AIR02 conclusions and next steps

Responses overwhelmingly supported our core proposal to use legislative powers to require the provision of audible and visible information onboard local services in Great Britain. However, in developing the Accessible Information Regulations, we will remain mindful of the reservations expressed by some operators and local authorities about the need for proportionality, to avoid damaging the very sector we seek to enhance.

Route identification and direction

Responses generally indicated agreement with the value of this information. Those in support highlighted that this information would particularly benefit those already on the vehicle to provide reassurance that they remain on the right route, and passengers boarding to identify their intended service. However, concern was expressed about this information being repeated frequently. Having weighed the reservations expressed, and the value of this information to passengers, we remain of the view that its provision should remain part of the core requirement.

Upcoming stops

Of all the information categories discussed, the announcement of upcoming stops was the least contentious amongst respondents. Some respondents highlighted the challenge presented by routes with frequent stops, both in terms of the technical feasibility of distinguishing distinct stopping places, and the desirability of presenting what some saw as a constant stream of information.

However, we remain of the view that next stop information can support passengers in knowing that, regardless of the local service vehicle they board, they will have the information they need to alight at their intended stop. Therefore, the Regulations must require that every scheduled stop is announced.

Stop names

A number of stakeholders highlighted the need for consistency in the names of stops announced audibly and visibly on-board services. However, feedback also suggests that relying on information already available in the National public transport access nodes (NaPTAN) database is likely to result in an overly rigid approach to determining what information is provided. With this in mind, we will not make use of NaPTAN a requirement in the Regulations, as this would risk stifling industry innovation and operator flexibility. Doing so would also go further against our technology neutral approach by tying the Regulations to a specific database. However, we recognise the use of NaPTAN in supporting consistency of information provision and will recommend its use to operators in guidance.

Additionally, as with other aspects of the requirement, we would not prevent operators from embellishing required information, provided it doesn’t compromise the original information. For example, a standard stop name could have additional information such as a colloquial name or reference to a local landmark.

Terminating stops

We agree with DPTAC’s suggestion that stops where services terminate should be provided audibly and visibly. As such, we will include provision for the service destination to be announced and displayed alongside the route number. This will include a requirement for services with no fixed final stopping place, such as those with circular routes, to provide information which indicates the direction of travel. We will also require that the definition of a terminating stop includes situations in which the service has ended in a place which it wasn’t scheduled to terminate. This intends to provide disabled passengers with vital information, removing uncertainty about the journey.

Information on diversions

Stakeholders representing operators stated that it would be difficult and expensive to provide detailed diversion information. It was noted that drivers tend to not know about the diversion until arriving at the road closure, and even if they were aware, that doesn’t guarantee they would have up-to-date knowledge to assist passengers. Our proposal was not intended to suggest that detailed missed stopped information should be provided as a substitution, as this would be beyond the ability of many systems and operational facilities.

However, stakeholders representing passengers expressed the view that information which enables passengers to make informed decisions prior to the commencement of a diversion is likely to be of value in allowing them to travel with greater confidence and to avoid inconvenient detours.

With this in mind, we propose that diversion information is provided in situations in which the driver is aware of the diversion before the service commences (planned diversion) and those which they are not aware (unplanned diversion). For both planned and unplanned diversions, we will require that information is provided to notify passengers that the service is on diversion. For planned diversions, we will require that information is provided to notify passengers that a diversion is about to commence prior to the last stop on the scheduled route before the diversion begins. To be mindful of the frequency of announcements, we will not require that an operator announces when a diversion has ended, as we expect that the next scheduled stop announcement will inform passengers that the route is no longer diverted. To be clear, it is not our intention that operators should be required to provide detailed guidance on stops missed and visited, although guidance will recommend that this should be provided where it is possible to do so.

We believe that this is a proportionate approach to diversions, in which the provision of basic information is required to simply inform passengers of the existence of the diversion, enabling them to seek further information from the driver as required.

Information on connecting services

Though respondents acknowledged that information about connecting services may be beneficial for passengers, the majority agreed with our proposal not to provide this information at present. Respondents expressed concerns about information overload for passengers with visual impairments, autism, or learning disabilities.

Therefore, we do not currently intend to mandate the provision of information about connecting services in the legislation. However, we will highlight in guidance the role that such information can play in helping passengers to make end-to-end multi-modal journeys.

Timing of information provision

Proposal

We recognised the diversity of local service routes across the country, and aimed to prioritise the specification of desired outcomes, rather than specific locations or times wherever possible. Therefore, we proposed that the regulations should specify the points when the required information must be provided during a service, such as:

• information identifying the route and direction should be provided when the vehicle is waiting at a stop
• information identifying stops should be provided for every stop at which the service is called
• the timing of the information to enable passengers to indicate to the driver their intention to alight at the respective stop

AIR03: Response summary

Do you agree that the proposed information timing requirements are appropriate?

Total percentage (%) responses

• Yes: 68%

• No: 16%

• Don’t know or no response: 16%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	10	5
Passengers	32	7
Local authority	19	3
Other	8	1

AIR03: Response analysis

Over two thirds of respondents agreed with our proposals, including 66% of respondents representing operators and over 80% representing passengers.

The most common responses indicated concern about the amount of information which should be provided. This included the need to strike a balance between meeting the information needs of disabled passengers and avoiding creating information overload for other travellers, and the need to see that every stop is announced. Both cases were spread across the stakeholder categories.

Passenger experience

A range of views were expressed regarding the individual data types covered by this question. Respondents were split, for example, on the value of route and destination information provided at the point of boarding, and on the specific priorities for the timing of diversions information.

Identification of route and direction

On this point, respondents fell into two groups. The first group consisted of those who agreed that such information should be provided but who felt that the required timing should be adjusted to reflect the variation in service dwell times at stops and different passenger needs. They highlighted the risk of announcements repeatedly cut short by closing doors, of long queues of boarding passengers unable to hear announcements, and of deaf passengers being unable to access information until they have been seated.

The second group consisted of respondents who felt that the provision of such information was unnecessary, either because passengers would use other means to identify a service, or because the challenge of accessing it at the point of boarding made the information irrelevant.

Identification of each upcoming stop

The importance of next stop information was emphasised particularly by stakeholders representing disabled passengers, who saw it as key to making services genuinely accessible. The majority of respondents also supported our proposal to require every stop to be announced, noting that such a consistent approach was vital for providing passengers with confidence.

Several respondents highlighted the challenges of announcing every stop on routes with frequent stops, with one authority suggesting that intermediate stops might need to be omitted in order to avoid a constant stream of information, though recognising that this could impact negatively on accessibility:

The bus stops are relatively close to each other and in the event of the bus not stopping at a bus stop, the bus stop announcements were given out quickly and continuously and it could become confusing for passengers when to disembark the bus.

Respondents also commented on the alignment between audible and visible information. A large transport authority experienced in supporting the provision of accessible information on services noted that the trigger points for audible and visible messages were likely to be different and recommended that government learns lessons from authorities and operators with existing knowledge of such provision to support effective timing of the required information.

Identification of diversions

Comments on the identification of diversions largely mirrored those of the previous question, noting the many challenges of specifying a requirement which was workable in every conceivable context. Respondents felt that information would only be useful if it was provided before the final stop preceding the diversion, whilst noting that it would need to be repeated, perhaps multiple times, for the benefit of boarding passengers. Stakeholders representing passengers also suggested that the information would only be of use if it included details of the stops that would be missed out, though some conceded that this might only be possible if drivers were trained to make announcements manually.

Cost

Though cost-related concerns were not predominant in responses to this question, one respondent commented that if smaller operators struggle to offer the same standards as larger ones, they would be likely to lose out when tendering to operate subsidised routes and will thus be forced out of business. However, this concern was not widely expressed.

Implementation practicality

A few respondents raised concerns about the audible and visible component of announcements being timed together, however this was not a widely expressed view. Others emphasised the importance of ensuring that the frequency and timing of audible announcements are given careful consideration. Finally, as discussed in other sections, the issue of diversions was predominant, with respondents commenting on the difficulty of announcements for unplanned diversions.

AIR03 Conclusion and next steps

The information timing proposals were intended to strike an appropriate balance between providing sufficient information to enable passengers to make decisions based upon the information, but not to the extent that it creates a challenging environment for other passengers. The outcome-focussed approach was supported, although views on how that outcome should be achieved differed.

Information identifying the route and direction

Respondents representing passengers confirmed our view that information identifying the route and direction can help passengers develop confidence that they are boarding and travelling on the right service. However, many felt the timing was most use for passengers boarding services, yet others felt it had greatest use for those already on board.

We will therefore require in regulations that respective information is provided when the passenger doors are opened. This intends to allow operators flexibility with when to provide the information based on a trigger point, given that some services will be at a stop for a matter of seconds, whilst others for minutes. This will require the operator to base the timing of the information on how a passenger interacts with the vehicle when entering, but it will also mitigate operators needing to repeat the same information at the same stop, should there be a queue to board the vehicle.

Announcement of upcoming stops

A number of stakeholders representing passengers drew comparisons with the provision of announcements on rolling stock, suggesting that upcoming stops are announced when the doors are open at the previous stop, and repeated again before the next one. However, we note that local services are fundamentally different from railway ones, in the spacing of stopping places and in the practice of missing out stops where passengers neither need to board nor alight. Therefore, it would be impractical to set a requirement to announce the next stop when the vehicle has paused at the previous one.

We wish to see services where essential information is always available to passengers, whilst avoiding requirements which add cost and complexity without a strong case for their inclusion. Therefore, we will pursue the approach outlined in the consultation proposal that next stop information must be delivered in sufficient time to enable passengers who wish to indicate their intention to leave the vehicle to the driver before it is too late for the vehicle to stop.

Stakeholders also raised the treatment of “hail and ride” sections of routes, where vehicles may stop in any safe location to allow passengers to board or alight. We agree that information about “hail and ride” services are important so that passengers understand the type of service they are on. However, given the fluidity of “hail and ride” services, in which there are no scheduled stops, there are challenges in providing detailed information on the route. Therefore, we will require operators to provide information at key points to notify passengers that the service is operating as a “hail and ride” route. This will be required at the proceeding stop before the service transitions to a “hail and ride” service and, if the service transitions from a “hail and ride” service to a scheduled route, in sufficient time to allow passengers to alight at the first scheduled stopping place on the scheduled route.

Information about diversions

We have summarised our response to diversions, including the timing requirements, under AIR02.

Quality of information

Proposal

We proposed that the quality of information should be defined with reference to a “specimen person” with average vision and hearing. A specimen person should be able to access information provided audibly and visibly from the furthest point on the vehicle from the nearest source of that information, including on both decks of a double deck vehicle. This should include a specimen person seated in a wheelchair in a backwards facing wheelchair space. We also proposed that the information should be accessible to a person using the ‘T’ function induction loop setting on a working hearing aid.

AIR04: Response Summary

Do you agree that the proposed use of a “specimen person” is the most appropriate way to ensure that information provision is of an adequate quality to be of use to passengers?

Total percentage (%) responses

• Yes: 64%

• No: 14%

• Don’t know or no response: 22%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	11	3
Passengers	30	6
Local authority	17	3
Other	7	2

AIR04: Response analysis

For this question, almost two thirds of respondents answered that they agreed with the proposed use of a ‘specimen person’ to ensure the adequacy of information provision. This included over 78% of respondents representing operators, and over 86% representing passengers. The majority of responses focussed on the technicalities of the concept of the ‘specimen person’, and how it could be used to support all travelling passengers to access the information provided.

Passenger experience

Several respondents commented that visible information should be provided across the whole vehicle, and, as a minimum, be visible from all priority seating.

Respondents widely expressed that wheelchair users travelling in the wheelchair space should be able to access both the audio and visual announcements, with the screens being fully visible in those spaces. The availability of visible information in rear facing wheelchair seats is explored further in the next question.

The issue of differing internal noise levels between vehicles was also raised by a few respondents, who felt that the use of the ‘specimen person’ concept didn’t account for this. It was commented that systems must vary the volume of announcements according to different conditions to balance the needs of drivers and passengers.

Technical detail

Concerns about the definition of ‘specimen person’ were widely expressed. A local transport authority commented:

We consider that specifying ‘average vision and hearing’ might be problematic, and would fail to meet the needs of passengers with vision and hearing problems, but are not sufficiently disadvantaged to consider use of an audible loop.

A number of respondents also commented that the needs of all passenger groups should be considered and using a specimen person was not entirely appropriate.

The issue of minimum standards for visual and audio announcements was also predominant. Several respondents, spanning all stakeholder groups, commented that characteristics such as colour contrast, screen brightness, size of text and volume, should be standardised.

Implementation practicality

Concerns surrounding the practicality of implementing the concept of the specimen person were raised by several operators and local authorities, who commented that the requirement that a person should be able to hear and view information from anywhere on the vehicle is unlikely to be practical. However, several of these respondents also acknowledged the importance of wheelchair users travelling in the wheelchair space being able to access both audio and visual announcements.

AIR04: Conclusions and next steps

The majority of respondents agreed that use of a specimen person was an appropriate way to ensure the adequacy of information provision, this included more than three quarters of operators and 86% of passengers. However, we agree that the use of a specimen person risks inadvertently excluding disabled passengers, dependent on the criteria for what constitutes a ‘specimen person’.

Whilst we agree that noise levels and sight lines in vehicles will differ, which makes it complicated to provide for every potential scenario in Regulations, we accept that the specimen person may not be the most appropriate means of achieving an adequate minimum standard. Defining “average” is challenging and could suggest inadvertently that we are not focused on achieving accessible outcomes for disabled passengers. We have been reluctant to date to set technical requirements for information provision, fearing that it would undermine our technologically neutral approach. However, we recognise that it may provide consistency and clarity to passengers, developers, and suppliers of onboard information provision solutions.

Instead, we will broaden the outcome-based approach so that it is focussed on the passengers’ collective access to the information, rather than a specific person’s access to it. In doing so, we will set parameters for how the information must be provided, so that the quality of information reaches a minimum standard across services. We intend for these requirements to still allow operators flexibility in how they comply, including use of non-technological solutions for the most part.

With this in mind, we will reflect in regulations that the visible information must be provided within line of sight of 51% of seated passengers on either deck of the vehicle, including all priority seating and forward-facing wheelchair spaces. This is intended to direct operators to position visible information in an appropriate place in the interior of the vehicle where it can benefit passengers. To deliver information of a standard that can be used by passengers, we will also specify the minimum character height, that it doesn’t use any word in capital letters only, and that it contrasts with its background.

For visible information available to passengers in a backwards facing wheelchair space, we agree that it is important for mobility-aid users – especially those with hearing-impairments – to have access to this information. However, we also acknowledge the additional cost and practicalities on operators of providing visible information for passengers facing backwards. Therefore, we will require that provision of visible information available to passengers in a backwards facing wheelchair space must be provided on any vehicle first used from 1 October 2023 (to align with the first implementation date for the regulations). This intends to reduce the burdens on operators in retrofitting their existing fleet while extending the provision of visible information to wheelchair users in the coming years.

We will also specify in the regulations that the audible information must be louder in specified decibels than the ambient volume of the vehicle. This intends to mitigate stakeholder concerns that not all vehicles emit the same volumes, especially when comparing a diesel engine to an electric one. We understand that some systems allow for the volume of the audible information to be automatically altered, depending on the surrounding noise of the vehicle. However, not all operators will install such systems, and we do not intend to specify that they must do so. Therefore, we will specify that vehicles without adaptive volume control base the average ambient volume on the vehicle when it is travelling at a specified speed in certain conditions. To mitigate the risk that the information provided is too loud, we will specify an overall maximum volume. This will be based on the requirements as set out under the Control of Noise at Work Regulations 2005, recognising that drivers will be exposed to the audible information throughout their working day.

AIR05: Response summary

Do you agree that the Regulations should require that a person using a hearing aid in conjunction with an audible induction loop system should be able to discern audible information?

Total percentage (%) responses

• Yes: 64%

• No: 9%

• Don’t know or no response: 27%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	8	4
Passengers	35	1
Local authority	16	2
Other	6	2

AIR05: Response analysis

For this question, just under two thirds of respondents agreed that a person using a hearing aid in conjunction with an audible loop system should be able to discern audible information. This included two thirds of operators, and over 97% of organisations representing passengers.

Passenger experience

There was widespread support for this aspect of the proposal, with respondents across all stakeholder groups acknowledging the benefits it would confer on passengers.

Many respondents also commented that the requirement would further benefit disabled people by reducing stress, the fear of missing stops and the need to rely on other passengers.

Cost

Cost was a major concern for a number of respondents, primarily operators. A large operator remarked:

Fitting an entire double deck bus with inductive loops is very expensive, with costs of £12,000 per bus.

A local authority expressed concerns that the cost implications of installing the equipment could result in operators raising fares, pulling out of delivering marginal services or requesting council subsidies. This was a concern raised particularly regarding smaller operators.

Another large operator, also citing costs concerns, recommended:

[We] consider it to be appropriate to provide this capability on the lower deck of all vehicles towards the front of the vehicle, otherwise the costs would be prohibitive.

Enforcement efficacy

A handful of respondents raised the issue of the enforcement and regulation of the requirement. An organisation representing the interests of disabled people commented:

This regulation should not only mean that a loop system is installed. Our recent work demonstrated that loop systems need to be carefully positioned on buses so that vehicle noise doesn’t cause interference.

AIR05: Conclusion and next steps

Responses to this question were generally supportive of the principle of requiring information to be provided via this method, although a number of operators highlighted the cost implications of applying it across the entire vehicle. The provision of audible and visible information via speakers and screens would benefit many passengers, but without the addition of a hearing loop in at least part of a vehicle, some passengers with dual sensory loss may not be able to access it at all. Induction loops will also benefit passengers who may struggle to discern audible announcements in a loud public environment. Therefore, we propose to require in the Regulations that audible information is made available via induction loops to passengers seated in all priority seating and in the wheelchair space. Whilst we will not require its provision in other areas of the vehicle, we will consider how to reflect the desirability of doing so through guidance.

Use of technology

Proposal

We proposed that information which relied upon a passenger purchasing or possessing smart devices would be insufficient to meet the requirements of the proposed legislation. Even so, we proposed that the regulations should not prevent digital services from being provided in addition to appropriate provision of audible and visible information. We also proposed that the Regulations should not prevent the use by operators of personal smart technology where it was provided for free to any passenger boarding the vehicle.

AIR06: Response summary

Do you agree that it would currently be inappropriate to require passengers to purchase or possess smart devices in order to access required information?

Total percentage (%) responses

• Yes: 81%

• No: 9%

• Don’t know or no response: 10%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	10	3
Passengers	41	4
Local authority	21	2
Other	10	0

AIR06: Response analysis

Over 80% of respondents agreed that passengers should not be required to purchase or possess a smart device in order to access required information. This included 77% of operators and 91% of organisations representing passengers.

The majority agreed it is inappropriate to place the responsibility on the passenger to provide the means of access to audible and visible information and therefore partially removing the requirement from the operator. However, a significant number of respondents expressed the view that the option should be explored in the future.

Passenger experience

Many respondents indicated that requiring passengers to use a smart device to access audible and visible information would be discriminatory, and therefore detrimental to passenger experience, as take-up of smart phones remains low amongst older and disabled people.

However, a significant number of respondents expressed the view that information could be made available for those with smart devices, as long as that was not the sole medium of accessing it.

Cost

The prohibitive cost of owning a smart phone was raised by several respondents. However, a significant number of respondents also commented that the option should be explored, due to its possible cost-effectiveness.

Implementation practicality

The primary concerns surrounding the implementation of smart devices were related to poor connectivity in rural areas and gaps in mobile coverage.

AIR06: Conclusion and next steps

Respondents to this question overwhelmingly supported our proposition that operators should not be able to rely on passengers possessing smart technology in order to provide information required by the regulations, pointing to the low rates of smartphone ownership and familiarity amongst target groups.

Respondents also discussed the desirability of giving operators the freedom to provide passengers with devices with which to access information during their journeys, rather than relying on information broadcast via screens and speakers. We note the benefits highlighted by respondents, including the potential cost effectiveness of such a solution, but also the risk that passenger unfamiliarity with devices would limit their effectiveness.

With this in mind, we will require the provision of information in a manner which is not reliant on smart phones. However, operators will not be prevented from providing passengers with personal technology as an additional form of communication to that required in the regulations.

Use of exemptions

Proposal

We explained in the consultation our intention for the new requirement to apply across the majority of local services and reiterated our intention to avoid widespread exemptions for large swathes of the industry. However, we noted that, whilst the provision of accessible information was important, it should not compromise the continued viability of services.

We therefore proposed that exemptions should target four categories of service:

• services run under Section 19 and 22 permits
• services provided by vehicles designed to carry fewer than seventeen passengers
• tour services, as defined by the Public Service Vehicles Accessibility Regulations (PSVAR)
• services provided by heritage vehicles, defined as those first used before 1st January 1973

In all cases, we proposed that exemptions included in the regulations should be applied uniformly across Great Britain.

AIR07: Response summary

Do you agree that vehicles operated under Section 19 and 22 permits should be exempt from the requirements in full?

Total percentage (%) responses

• Yes: 50%

• No: 20%

• Don’t know or no response: 30%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	8	7
Passengers	23	8
Local authority	13	4
Other	7	1

AIR07: Response Analysis

Respondents were split on this question, with 50% agreeing that vehicles operated under Section 19 and 22 permits should be exempt from the requirements, 20% disagreed, and the remaining 30% were either unsure or did not respond. Out of those who responded, over half of operators agreed, and just under half disagreed. However, respondents representing passengers were less divided, with 74% agreeing with this aspect of the proposal.

Passenger Experience

Stakeholders who supported the exemption for the Section 19 and 22 permit holders cited the reason that many vehicles which operate under these permits are small enough for passengers to communicate directly with the driver.

Those who disagreed cited the need for consistency amongst local services. There were also respondents who felt that, whilst Section 19 and 22 operators should be encouraged to install audible and visible technology, this shouldn’t be a mandatory requirement.

Cost

A number of respondents commented that the cost of providing audible and visible information would be unaffordable for operators with Section 19 and 22 permits, and for this reason they supported the proposal to exempt those operating under these permits. In what was a typical response, a local authority remarked:

Community Transport operators often use smaller vehicles, provide a more personal service (drivers can interact with passengers) and the requirement to provide accessible information on them would be disproportionate, and potentially detrimental to their continued viability. On this basis we agree that Section 19 and 22 operators should be exempt.

This was a view expressed widely amongst both local authorities and operators.

Technical detail

A number of operators felt that the exemption should be designed according to the size of the vehicle, as opposed to whether or not it operated under a Section 19 or 22 permit.

Communication

As mentioned in the passenger experience section above, the ability to communicate easily with the driver of a vehicle operating under a Section 19 or 22 permit was cited widely as a primary reason for exempting these vehicles from the upcoming accessible information requirements.

AIR07: Conclusion and next steps

Respondents who agreed with the exemption for vehicles which operate as Section 19 and 22 services cited the services’ inherent nature, which enables passengers to directly communicate with the driver. A few respondents raised concern about how the disproportionate costs on operators may harm their financial capability to continue running these types of services.Conversely, respondents who disagreed with the proposed exemption informed us that many services which operate under Section 19 and 22 permits are commercial services and recommended a size exemption would enable the protection of marginal services.

Although we acknowledge that, operators of Section 22 services often have less financial and operational resource than for profit operators. However, to many passengers, vehicles operating under Section 22 permits serve the same purpose as standard local services as they operate under routes and via ticketing which is of similar standard to other local services. Therefore, we intend to amend the proposed exemption by requiring that only Section 22 vehicles first used from 1 October 2024 must comply with the Regulations. This intends to balance the information needs of passengers, ensuring that over the years, they will have access to onboard information, whilst mitigating any implications on Section 22 operators in needing to retrofit their existing vehicles. By applying the requirements to new vehicles, we expect that Section 22 operators which do purchase a new vehicle will have the finances to also comply with the regulations (given the relatively low cost of equipment to comply with the regulations in comparison to the cost of a new vehicle), and that applying an exemption for existing services will safeguard those operators which cannot afford to comply.

Additionally, the protection of section 19 services can be accomplished through a single vehicle size exemption. Therefore, we intend to remove the proposed exemption for services operating under Section 19 permits.

AIR08: Response summary

Do you agree that vehicles carrying fewer than seventeen passengers should be exempt from the requirements in full?

Total percentage (%) responses

• Yes: 50%

• No: 30%

• Don’t know or no response: 20%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	11	5
Passengers	22	15
Local authority	13	8
Other	5	2

In line with the previous question, only half of respondents agreed that vehicles carrying fewer than seventeen passengers should be exempt from the requirements. Of those who responded, 69% of operators, 59% of organisations representing passengers, and 62% of local authorities were in favour of the proposal.

AIR08: Response analysis

Passenger experience

As in the previous question, respondents who agreed with the exemption cited the relative ease with which passengers can communicate with drivers on smaller vehicles, negating the need for audible and visible announcements.

However, there were a significant number of respondents who felt that there was no justification for exempting vehicles based on their passenger number capability. A few respondents were especially concerned about the likelihood of an increased prominence of vehicles carrying fewer than seventeen passengers due to increased demand responsive transport. Consequently, they saw that the provision of audible information should be applicable.

Cost

Several respondents agreed with the proposal to exempt smaller vehicles cited the cost of implementing audio and visible information as the primary reason for doing so. These respondents felt that it would be a significant financial strain on operators with smaller vehicles.

Implementation practicality

A concern that was highlighted by a number of respondents, spread across the different stakeholder groups, was that the larger operators may switch some of their least popular services to smaller vehicles with a capacity of less than seventeen passengers to avoid the cost of installing audible and visible equipment.

Enforcement efficacy

Standardising between the forthcoming Accessible Information Regulations and the Public Service Vehicles Accessibility Regulations (PSVAR) as to the size of a “small vehicle” was an issue recurrent in responses. It was suggested this would provide greater clarity for members of the public on vehicle sizes and the level of accessibility they can expect.

A handful of respondents suggested that the government monitor the impact of this exemption, with a view to withdrawing it at some time in the future should evidence demonstrate that this is necessary. An organisation representing the interests of disabled people recommended that if the use of smaller vehicles and minibuses does become more common amongst larger operators, the exemption may require review.

Communication

Respondents that agreed with the proposal cited the ease with which drivers could communicate with passengers as a significant reason for exempting for smaller vehicles.

AIR08: Conclusion and next steps

Some stakeholders who accepted the need for smaller vehicles to be exempted from the Regulations questioned the threshold we proposed to apply, pointing to the requirement that vehicles be “designed to carry more than twenty-two passengers” in order to be within scope of the Public Service Vehicles Accessibility Regulations 2000 (PSVAR). However, whilst there may be exceptions, we are of the view that allowing ‘large buses’ under the twenty-two-seat threshold to operate without the provision of audible and visible information, yet without a consistent alternative of a personalised experience offered on ‘small buses’, would exclude any benefits to passengers.

We note the feedback received from stakeholders during the consultation events in Scotland, which highlighted the particular reliance on local services provided by smaller vehicles in the most isolated areas of Great Britain. These discussions highlighted how the financial costs of implementing the requirements could have a detrimental effect on operator sustainability, which would in turn affect those populations’ ability to remain connected with the wider transport network. We also recognise the additional challenges of providing visible information in a ‘small bus’ environment, with constrained sight lines and close viewing distances.

As such, in the regulations we will include an exemption for vehicles designed to carry sixteen or fewer passengers but will include in guidance recommendations on communicating with disabled passengers relevant to any local service.

AIR09: Response summary

Do you agree that tour services, as defined in the Public Service Vehicles Accessibility Regulations 2000 (PSVAR) should be exempt from the requirements in full?

Total percentage (%) responses

• Yes: 63%

• No: 13%

• Don’t know or no response: 24%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	15	1
Passengers	25	11
Local authority	19	0
Other	5	1

Response analysis

Responding to the question AIR09, 63% of respondents agreed that tour services as defined in PSVAR should be fully exempt from the requirements, while 13% of respondents did not agree with the exemption. Those respondents in agreement included over 90% of operators and all local authorities, whilst those who did not agree consisted mainly of passengers (85%). However, it is worth noting they only represented 31% of all passenger responses.

Passenger experience

32 respondents commented that tour services frequently include an audible commentary. This would make additional announcements unnecessary and could cause confusion for some passengers.

A few respondents commented that the incoming regulations should be used as an opportunity to increase the accessibility of tour services. However, an organisation representing disabled passengers agreed that exemptions would be acceptable for tour services as long as disabled passengers were able to enjoy them in the same way as other tourists.

Cost

Responses regarding the cost of implementing the required provision of audible and visible information were limited for this question. However, a local council did comment that operators had stated that they would raise the money required for the technology through increasing their tendering fees.

Implementation practicality

Responses regarding the implementation practicality of this proposal were also limited. However, one respondent representing the interests of disabled people commented on the need for a clear definition of tour services in order to prevent regular service operators disguising themselves as tour services for access to exemptions.

Technical detail

A small number of respondents who did not support exemptions for tour services provided suggestions on what accessible provisions they would like to see on tour services. Suggestions included the use of hearing loops and visual aids. The technical detail involved in the implementation of this policy, however, was not a recurring theme.

AIR09: Conclusion and next steps

Many respondents across different stakeholders supported our proposal, citing that many of these services already provide audible information on their vehicles to enhance the passenger experience. However, disabled organisation representatives recommended that the Regulations should be used as an opportunity for tour services to become more inclusive for all types of passengers. Additionally, they informed us about their concern of the current adequacy of tour services’ provision of audible and visible information, and the potential risk that a few operators may operate a regular service under the disguise of a tour service. However, this view was not widely expressed across stakeholders.

Whilst we see the merit of using the regulations as an opportunity to further develop accessibility in the sector of tour services, we are aware of the financial harm which the regulations could cause on the industry. Therefore, we remain of the view that tour services, as defined by the Public Service Vehicle Accessibility Regulations (PSVAR), should be fully exempt from the regulations. However, we recognise the risk of operators potentially using tour services to mask regular services, therefore we intend to monitor this exemption.

AIR10: Response summary

Do you agree that heritage vehicles should be exempt from the requirement to provide visible information, and heritage vehicles should be defined as those first used before 1st January 1973.

Total percentage (%) responses

• Yes: 69%

• No: 10%

• Don’t know or no response: 21%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	15	0
Passengers	28	10
Local authority	20	0
Other	7	0

AIR10: Response analysis

69% of respondents agreed that heritage vehicles, as defined as those first used before 1st January 1973, should be exempt from the requirement to provide visible information. Of those that did not agree with the exemptions (10% of respondents) consisted entirely of passengers, however they only represented 26% of total passenger responses, with the rest supporting an exemption for heritage vehicles.

Passenger experience

Ten respondents commented that, as a percentage of service journeys, heritage vehicles are insignificant. A large operator commented that it would be unlikely that passengers would be put at disadvantage from an exemption due to the limited use of heritage vehicles. A disability group commented that passengers on heritage vehicles typically stay for the whole journey as heritage vehicles are closer to tour services than regular services. However, a local council suggested that heritage vehicle exemptions should be determined by the frequency of use on regular registered services.

Cost

Five respondents cited costs in their answers as to why they supported exemptions for certain heritage vehicle services. A large national operator commented that heritage services should be exempt due to the larger financial contributions that would be required to install the necessary equipment in comparison to newer vehicles.

CPT also supported the exemption for heritage services on the basis of cost, given that retrofitting speakers would be very challenging for these vehicles.

Implementation practicality

31 respondents commented on various implementation issues of requiring heritage vehicles to comply with the regulations. Of these, 12 respondents commented that heritage vehicles would be very difficult to update. 11 respondents recognised the legislative difficulties in future-proofing heritage vehicle definitions. Eight further respondents commented that a number of vehicles would soon be approaching the heritage vehicle age who have yet to install the necessary equipment and suggested setting a minimum requirement of 25 years to be considered a heritage vehicle.

AIR10: Conclusion and next steps

Overall, responses to this question generally agreed with the exemption of heritage vehicles, citing the reasons of limited services, cost, and implementation practicality. A range of stakeholders supported the exemption on the basis that heritage vehicles have a restricted ability to run their services, therefore the risk of disabled passengers being widely disadvantaged is limited. Many respondents from local councils and operators commented on how the costs of fitting the necessary equipment and modern systems for the required provisions of information would create a financial strain on the charities and individuals who run these services. A few respondents suggested that a ‘a rolling exemption’ should be introduced instead of having a definitive date for how heritage vehicles would be defined. However, this could result in exemptions for vehicles which have similar design layouts to that of modern vehicles, and therefore similar cost and implementation practicalities of providing audible and visible information.

Therefore, will expand the original proposed exemption (which related to visible information only) and write in the Regulations that heritage vehicles (as defined by 1 January 1973) should be exempt from all of the requirements, as we do not want to impose unnecessary financial strain on these services.

Additional exemptions: Long-distance services and vehicles with existing audible-visible information provision

During our engagement with stakeholders whilst developing this consultation response and the associated Regulations, we have identified three additional services to apply exemptions to for some, or all, of the requirements.

Long distance services

There are a number of services – primarily operated by coaches – which are long-distance but have a portion of their route which is registered as a local service due to two or more stops being within 15 miles of each other. These services often transport passengers between urban locations with infrequent stops. As such, whilst a portion of their route is registered as a local service, the intention of these services is not one which a typical local service would provide (for example, with multiple frequent stops along a designated route from which prospective passengers can flag the vehicle down and pay for a ticket onboard).

Whilst audible and visible information may be of some benefit to disabled passengers on these services, not all long-distance services have a local service element to their route. Sections 181A-181D of the Equality Act 2010 only allows for the Accessible Information Regulations to apply to local services. Therefore, including long-distance services which have a part of their route registered as a local service would detract from our intentions for the consistent provision of information across the country – as some long distance services would have audible and visible information, whilst others would not. Furthermore, there is a risk that operators of these services would remove those portions of their route which require them to be registered as local services in order to not have to comply with the regulations. This could potentially take existing services away from passengers.

Therefore, we will provide an exemption for long distance services from all aspects of the regulations. In setting this exemption, we have been mindful of the criteria being sufficiently broad to apply to those services which are primarily long-distance with elements of local service stops within them, but that the exemption shouldn’t apply to those which are primarily local services but which have a few stops which are greater than 15 miles apart. In doing so, we have approached this exemption from a passenger perspective, in which they wouldn’t see the former being a local service, but which they would see the latter as being so. Therefore, the exemption criteria will be based on the total distance of local service stops being less than half of the total distance of the route.

Vehicles with existing audible and visible provision

We will apply an eight-year exemption from the technical requirements for vehicles which already provide a form of both audible and visible information. At present, 46% of buses in England provide onboard audible and visible information, and it is not our intention that these vehicles must be immediately re-fitted in the case that their systems do not allow for compliance with the audible and visible information requirements. This would put further burden on operators of these ‘partially compliant’ vehicles, and risks replacing existing systems which provide a suitable service.

However, this exemption will only apply to the technical requirements – such as those on the character height or decibel parameters – and to the requirements to provide division and hail and ride information. All other requirements, such as to provide information on upcoming stops, will apply to these services from the proposed date of commencement, 1 October 2023. Given that these vehicles already have a form of accessible information provision, it is reasonable that they must continue to provide information on the route and next stop from the date of commencement. As some systems have been tailored for providing specific forms of information on diversions and hail and ride elements of routes, we have decided not to require provision of such information for partially compliant vehicles.

To be clear, this exemption is intended to mean that, where audible and visible information is already available to passengers it continues to be provided. It seeks to assure passengers that the provision of such information cannot be withdrawn at the whim of an operator or authority, whilst avoiding requiring existing systems to undergo significant modification for at least eight years. We will set minimum criteria for the audible and visible information provided onboard “partially compliant” vehicles to be eligible for this exemption. Setting a minimum standard for such systems will mean that passengers using “partially compliant” services receive an acceptable level of information, of benefit to them.

“Closed door” home-to-school services

There are many “closed door” home-to-school services that members of the public cannot board. These services can be used only by school or college pupils or staff, or by people supervising or escorting another passenger. Generally, these services will have one destination on the outbound journey (the place of education) and will stop at the same places each day on the return leg.

Importantly, these services tend to be driven by the same person and serve the same passengers each day. This means that passengers can communicate their needs to a driver and reasonably expect a consistent level of service day-to-day. While the provision of audible and visible information might benefit some disabled passengers, it is unlikely that it would have a high impact.

We believe these benefits would be minimal compared to the financial cost to the operators of these services. This is particularly so given that the vehicles used to run these services are often older coaches that may be used for other exempted purposes during the day. Additionally, since these “closed door” services are not open to the public, our ambition for consistency of information provision across the sector is less relevant here.

As such, it does not seem proportionate or necessary for the aims of our policy to bring these services into the scope of the regulations. After considering the consultation responses and subsequent stakeholder engagement, we have decided to exempt “closed door” home-to-school services from the regulations.

We intend to define these services in the regulations along the same lines as the recent PSVAR medium-term exemptions. This will mean that home-to-school services which are open to the public remain in scope.

Additionally, is important to note that the exemption will apply to services rather than vehicles. Consequently, any vehicle that is used for “closed door” home-to-school services and in-scope local bus services will need to comply to deliver those in-scope services.

Implementation timescales

Proposal

We proposed that the date by which a vehicle must comply should depend upon when it was first used, and the size of its operator. The following implementation timescales have been amended from the original consultation to reflect a revised proposed commencement date of 1 October 2023, as opposed to 6 April 2019:

Standard operators (>20 Vehicles).

• vehicles first used after 30 September 2018: Must comply from 1 October 2025
• vehicles first used between 1 October 2016 and 30 September 2018: Must comply from 1 October 2027
• vehicles first used on or before 30 September 2016: Must comply from 1 October 2029

Small operators (<21 Vehicles).

• vehicles first used on or after 1 October 2023: Must comply from 1 October 2025
• vehicles first used before 1 October 2023: Must comply from 1 October 2029

We also proposed a transition period for operators which become a “standard operator” on account of growing their fleet size, to avoid creating disincentives for business growth.

AIR11: Response summary

Do you agree that the proposed implementation approach indicated above is the most appropriate of the three options identified?

Total percentage (%) responses

• Yes: 53%

• No: 19%

• Don’t know or no response: 28%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	4	8
Passengers	28	5
Local authority	15	4
Other	7	2

AIR11: Response analysis

Over half of respondents agreed that the proposed implementation approach was appropriate. Out of those respondents who agreed, organisations representing passengers made up 85%, however operators were more divided, with only a third agreeing with the proposed approach.

Cost

A significant number of respondents commented that operators will require financial assistance to deliver the implementation. An organisation representing disabled people remarked:

By making smaller bus companies comply, bigger companies may overtake these smaller companies as they have much larger funds to provide these accessible information platforms with more ease. We believe government should subsidise payment for these for smaller bus companies’ dependant annual turnover.

Another major concern was the difference in cost of retrofitting and purchasing new vehicles, especially the expenses incurred in retrofitting older vehicles.

Implementation practicality

Several respondents commented favourably on the balance this aspect of the proposal struck between timely implementation and financial considerations. Despite this, the timescales for implementation remained a contentious issue. Several responses reflected that the timescales were considered too long, and that the requirement should be introduced more swiftly. The distinction in the proposal between smaller and larger operators was also problematic for some. A large operator commented:

There should be no distinction between size operators. This is going to cause confusion to the passengers who will not be aware of the size of operator and therefore why certain buses will not be fitted with the equipment.

AIR11 Conclusion and next steps

Over half of the respondents supported our proposal. These mainly consisted of passengers, local authorities, and a third of operators. The sustainability of the timeframe was often cited as their reason of support, as the proposal enables operators to implement the necessary requirements whilst mitigating immediate financial harm. Whilst these respondents supported the proposed implementation timescales, the majority raised the need for financial assistance from the government to be able to successfully carry out these requirements at the expected pace.

Respondents who opposed the proposed timeframe were divided into three groups: those who saw the timeframe as too long, those who thought it wasn’t long enough, and those who believed there should a blanket requirement for all operators to follow the same timeframe.

Those who viewed the timeframe as too long were mainly organisations representing disabled passengers and local government bodies. We understand the need for the provision of accessible information to be implemented quickly, given that many passengers, both disabled and non-disabled, have waited for these benefits. However, we are conscious of its impact on the industry which has been heavily affected by the Covid-19 pandemic.

Respondents who believed the timeframe didn’t allow sufficient time to implement the required provisions highlighted the expense of retrofitting against procuring new vehicles with the required equipment already fitted. These respondents informed us about the process of retrofitting and how it will mainly occur during the second part of a vehicle’s lifespan, which in some cases creates a disproportionate cost against value for money.

After being informed about these recommendations, we will amend the implementation timescales so that they apply consistently to all applicable operators, regardless of the size of operator. This is due to the availability and use of the government’s £4.65 million A accessible information grant to support small operators to comply with the upfront costs associated with complying with the regulations. Therefore, we do not believe that there is an unfair disadvantage for these smaller operators, and passengers will start to benefit from the regulations sooner, no matter the size of the operator for their local service.

We will also amend the implementation timescales as follows:

• vehicles first used on or after 1 October 2019 must comply by 1 October 2024
• vehicles first used between 1 October 2014 and 30 September 2019 must comply by 1 October 2025
• vehicles first used between 1 January 1973 and 30 September 2014, must comply by 1 October 2026

We have developed these timescales to balance the need to provide consistent audible and visible information to passengers in a timely manner, with operator capabilities in doing so. Therefore, these timescales are based on the 17-year average lifespan of a local service vehicle, so that the provision of audible-visible information on newer vehicles will have a long lifespan, whereas operators are presented with the choice of either retrofitting their older vehicles or purchasing new ones which have equipment to comply with the regulations already installed.

AIR12: Response summary

Do you agree with our proposal to define “small operators” as those operating twenty or fewer vehicles?

Total percentage (%) responses

• Yes: 48%

• No: 28%

• Don’t know or no response: 24%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	6	9
Passengers	24	12
Local authority	14	7
Other	5	0

AIR12: Response analysis

For this consultation question, less than half of respondents agreed that “small operators” should be defined as those operating twenty or fewer vehicles. Out of the organisations representing passengers, over two thirds agreed with the proposal. Operators were more split, with 40% agreeing with the proposal and 60% disagreeing.

Passenger experience

Many respondents expressed the view that a ‘small operator’ category was unnecessary, and that the same regulations should apply to all operators of local services. As well as penalising large operators who have already invested in audio-visual equipment, it would also be discriminatory to passengers.

Cost

A very small number of respondents commented that the consultation was biased towards small operators and assumed that larger operators would better be able to absorb additional costs. However, this was not a view that was expressed widely throughout the responses.

Technical detail

Many respondents voiced their view that 20 was a ‘reasonable number’ of vehicles to be used as a cut-off point for smaller operators. This sentiment was expressed across the range of stakeholder groups.

The relatively small number of vehicles operating 20 or fewer vehicles was also raised amongst those who felt the number was reasonable. Several respondents felt that 20 was too large a number. Additionally, several respondents commented that the definition of a “small” operator should take into account both the number of vehicles operated, and the number of registered local services provided.

AIR12 Conclusion and next steps

We acknowledge that a quarter of respondents did not have an answer or didn’t know how to respond to this proposal, and less than half agreed with it. Those who disagreed with the proposed definition cited the category being unnecessary and argued that the regulations should apply to all operators simultaneously. Some respondents were concerned about the risk of discriminatory practice in a ‘large’ fleet of twenty vehicles, if it was not subjected to provide the required audible-visible information. Other respondents suggested that small operators could be defined on the numbers of routes they operated for greater accuracy. However, this view wasn’t widely shared amongst the stakeholders.

As explained under the conclusion for AIR11, we will not differentiate between large and small operators in setting the implementation timescales. This is primarily attributed to the government’s £4.65 million accessible information grant, and the benefits for passengers in a consistent roll-out of audible and visible information onboard local services across the country.

AIR13: Response summary

Do you agree with our analysis of the costs and benefits of the preferred option, as indicated in the consultation stage Impact Assessment?

Total percentage (%) responses

• Yes: 21%

• No: 19%

• Don’t know or no response: 60%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	1	11
Passengers	15	2
Local authority	2	6
Other	3	0

AIR13: Response analysis

For this question, 60% of respondents either did not know, or did not give a response. This was reflected in the comments, many of which cited uncertainty surrounding evidence and the confusing nature of the impact assessment. Over a fifth of respondents agreed with the cost and benefit analysis of the preferred option, and just under a fifth disagreed. Out of those who responded, more than 90% of operators disagreed, while 88% of organisations representing passengers agreed.

Cost

A significant number of respondents expressed the view that the costs included in the cost-benefit analysis were an underestimate. It was felt that the analysis did not factor in maintenance costs and overestimated the increase in patronage resulting from accessible information provision. A large operator commented:

The draft requirements are significantly more demanding in both hardware and software terms and therefore costs will be higher. For example, it would cost £12,000 to fit a vehicle with inductive loops to meet the specification.

The analysis’ assumption, that the proposed reforms will increase customer demand for local service vehicles, was also felt to be over optimistic. Additionally, the positive impacts of advertising were overstated according to several respondents. Respondents also raised concerns about the costs of retrofitting outlined in the impact assessment, stating that these too were underestimated.

Technical detail

A predominant concern across stakeholders was that the impact assessment did not contain enough detail or evidence in its estimates.

AIR013: Conclusions and next steps

Nearly two-thirds of respondents did not provide a response to this question. Out of those who responded, only a fifth agreed overall, with 88% consisting of passenger groups and only one operator.

Those respondents who disagreed with the analysis of the impact assessment cited the underestimation of cost and over estimation of the positive effects of advertisement and increased passengers. Respondents raised the issue that the real cost of implementing the regulations is far higher than suggested in the analysis. It has been suggested the heightened cost covers unaccounted areas, such as staff training, recruitment, and maintenance costs, particularly with retrofitting vehicles. A few respondents had suggested the positive effect of advertisement and increased passenger concision was an ‘over optimistic’ approach, and many rural bus services will not experience this effect in real contexts.

We recognise how the impact assessment has brought inconclusive answers to whether the analysis reflects the reality for operators’ ability to implement the regulations. The impact assessment was intended to lay out the options and provide general oversight of different policy options and their implications on stakeholders. Going forward, the department will continue to refine the economic analysis relevant to the policy so that the impact assessment for this response better reflects the cost of equipment and fitting and the financial reality for stakeholders.

AIR14a: Response summary

We are aware of at least one operator which has subsidised the ongoing cost of providing audible and visible information by using visible information displays to show advertisements. Please explain how effective you think such an approach could be in mitigating the cost of providing audible and visible information for other operators?

A response summary is not applicable to this question.

AIR14: Response analysis

Passenger experience

A significant number of respondents agreed that using visible information displays to show advertisements was an innovative idea. However, the majority of respondents stated that advertisements must not detract from the quality of audible and visible information being provided. Several respondents made recommendations on how to mitigate the potential negative effects of advertising. DPTAC recommended that, if advertising is used, it should be additional to the visual announcement, so that details on the screen are never replaced by advertising material.

Cost

Whilst some respondents did agree that the use of advertising to help mitigate costs of providing audible and visible information was prudent, the context-dependent nature of this approach was also raised. A community group commented:

Advertising revenue available will be very context sensitive, by geography, demographics, patronage levels, etc. It is also worth noting that the kind of display (and/or audio) that is suited to advertisement is not necessarily the same as that for bus service information, so any revenue is unlikely always to be a simple subsidy.

AIR14b: Response summary

We also understand that the cost of installing systems to provide accessible information can vary depending upon the vehicle and method of installation. Please comment on the difference in cost between procuring new buses with systems to provide audible and visible information already installed, and retro-fitting related equipment.

A response summary is not applicable to this question.

AIR14b: Response analysis

Passenger experience

A few organisations representing the interests of disabled people commented that cost should not be a concern in making travel easier and more comfortable for everyone.

Cost

The majority of respondents commented that retrofitting would always be more expensive. This was a view expressed across all stakeholder groups.

AIR14a and 14b: Conclusions and next steps

Many responses for both questions have suggested the need for flexibility and detailed guidance for operators to choose which methods are appropriate for their vehicle and route environment. As discussed in further detail, we have been informed by respondents how operators could use advertisement to subsidise implementation costs and the cost differences between procuring new vehicles with required equipment or retrofitting current vehicles.

Advertisement

Respondents generally supported the option of using advertisement on vehicles to help subsidise the implementation costs of the Regulations. Those who expressed concerns about the use of advertisement fell in two groups, those who viewed the estimated benefits of advertisement as presented in the impact assessment was an overestimate to real circumstances, and those who were concerned about the risk of creating sensory overload for all passengers, particularly neurodivergent passengers. However, this question was intended to explore the option of using advertisements to help reduce operators’ costs, and we remain of the view that some operators will see the benefit of using this approach. Therefore, use of advertisements will be presented as an option for all operators to use if they wish to do so. We will work with industry experts and stakeholders to develop guidance for the main contexts of using advertisement effectively without compromising the quality of the required information.

Retrofitting

An overwhelming majority of responding stakeholders stated that retrofitting current vehicles is the most expensive option due to the variation of equipment and software between vehicles and long-term maintenance costs. A few respondents stated that when new vehicles are procured, there would be a small fee to include additional equipment, such as the audible-visible information. This fee would be smaller compared to the fees of retrofitting current vehicles. Stakeholders often reference the vehicle’s lifespan as a key variable to the level of installation cost, stating that new vehicles will have better value for money compared to vehicles being retrofitted (which would typically be in the second half of their life). We recognise that operators will have different financial capability to implement these Regulations based on whether they are able to choose between procuring vehicles or retrofitting current vehicles. As a result, we will write the regulations so that a vehicle must comply by a certain date based on when that vehicle was first used by. This will provide operators with a choice on whether to retrofit that vehicle or purchase a new one with equipment already fitted to enable an operator to comply with the regulations.

Guidance for operators

Proposal

The Secretary of State has a duty under Section 181C of the Equality Act 2010 to publish voluntary guidance to accompany the new regulations.

We proposed that guidance should be developed to:

• recommend options for fulfilling the legal duties
• support operators to understand and fulfil the information quality requirements
• explain how to apply to the Secretary of State for exemption from the requirements
• Support passengers to understand what accessible information will be available and how to report non-compliance

AIR15: Response summary

Do you agree with our proposed content for the guidance? Please explain your answer, providing examples of potential content where appropriate.

Total percentage (%) responses

• Yes: 63%

• No: 11%

• Don’t know or no response: 26%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	8	4
Passengers	31	5
Local authority	19	2
Other	6	0

AIR15: Response analysis

For this question, 63% of respondents agreed with the content of the guidance, whilst 11% disagreed. Over a quarter of respondents either did not know or did not provide a response. Out of those who agreed, 86% were organisations representing passengers, and 66% were operators.

Passenger experience

A small number of respondents commented that it was important the guidance was made simpler for passengers to be able to understand. An organisation representing the interests of disabled people suggested that two guidance documents should be produced: one for operators, and one for passengers. That the guidance should be co-produced with disabled people was also a point that was raised. However, these sentiments were not expressed widely.

Technical detail

Several respondents commented that the guidance needed to be more extensive, in order for it to be beneficial.

AIR015: Conclusions and next steps

The majority of respondents supported the proposed content features, covering: recommendations for operators to fulfil legal duties, information quality requirements, explanation of how to apply for exemptions, and supporting passengers how to understand what accessible information will be available and how to report non-compliance. Many respondents cited the content as necessary for both operators and passengers to understand how the Regulations have impacted their services.

It was widely expressed across respondents that, for the guidance to have maximum value to stakeholders, there should be a collaborative approach towards its development. We see the merit in this suggestion and intend to engage with stakeholders, including DPTAC, when developing this guidance, thereby ensuring the document accurately reflects the level of detail and flexibility desired by stakeholders.

Compliance and enforcement

Proposal

The consultation document explained that the amendments to legislation, introduced by Section 17 (4) – (6) of the Bus Services Act 2017, provided the Traffic Commissioner with powers to enforce the Accessible Information Regulations. Operators found to be in breach of the requirements would have a right of appeal to the Upper Tribunal in England and Wales, and to the Transport Tribunal in Scotland.

Whilst the Accessible Information Regulations would not deal with enforcement, we proposed that guidance should be used to specify a process for complaining about alleged non-compliance and to ensure that the Traffic Commissioner understands the government’s preference for the regulations to be enforced in a proportionate manner, targeting sustained, deliberate non-compliance rather than short-term or inadvertent breaches.

AIR16: Response summary

Do you agree with our proposed enforcement principles?

Total percentage (%) responses

• Yes: 61%

• No: 16%

• Don’t know or no response: 23%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	12	3
Passengers	28	6
Local authority	17	6
Other	5	1

AIR16: Response analysis

Two thirds (61%) of respondents agreed with the proposed enforcement principles. Out of respondents, this included 80% of operators, and 82% of organisations representing passengers.

Passenger experience

A number of respondents expressed the view that passengers should be well informed on how to make complaints.

An operator commented:

Customers should be encouraged to supply sufficient detail to enable a fair and effective investigation by the operator, arbitration body and Traffic Commissioner. For some disabled customers, such a process will present difficulties. Methods of enabling people to register complaints effectively need to be considered for all the stages in the complaints process.

Technical detail

As per the previous question, several respondents felt that the enforcement principles did not go far enough, particularly regarding non-compliance. An operator commented:

Additional detail is required on timeframes for dispute resolution e.g. after 14 days an unresolved case should escalate from the operator to the Traffic Commissioner. In addition, the DfT needs to provide the Office of the Traffic Commissioner with additional resources to police this – otherwise it’s enforcement in theory only.

Enforcement efficacy

A significant number of respondents, largely local transport authorities, felt it was important that the enforcement onus was placed on the Traffic Commissioner, and didn’t rely disproportionately on passengers. However, some respondents also commented on the practicality of enforcing compliance under the powers of the Traffic Commissioner.

AIR16: Conclusions and next steps

Most respondents across different stakeholders supported the proposed enforcement principles whilst highlighting the need for a clear and detailed process for passengers to report effectively. A few respondents raised the point that multiple communication channels should be used to inform passengers about their rights and the complaint procedure.

Respondents placed emphasis that it should be up to the Traffic Commissioner to investigate complaints rather than disproportionately place the responsibility on passengers. Others raised the issue of the Traffic Commissioner’s limited capacity to carry out non-compliant reports and suggested exploring the option of using passenger organisations as an intermediary.

We recognise the challenges of enforcing a complaint procedure which would be accessible to passengers and proportionate to the complaint and believe that a clear enforcement procedure is essential for the regulations to be consistently implemented across England, Scotland, and Wales.

However, we acknowledge the resource and juridical limits of the Traffic Commissioners. We intend to work with Bus Users UK and the Traffic Commissioners to develop a clear and specific process for passenger complaints and reports that deals with cases of non-compliance in a fair and effective manner.

Extent of regulations

Proposal

The consultation document explained that, consistent with other measures in the Equality Act 2010, Sections 181A to 181D, would apply in England, Wales and Scotland. The powers allowed the Secretary of State to make different provision in different areas and so it would be possible, in theory, to reflect in the Regulations any significant differences in the nature of the local service market, passenger need, or other factors in the three nations.

Having developed the draft requirements in consultation with the Scottish and Welsh governments, and with stakeholders in Scotland and Wales, we determined that the differences identified, most notably in the nature of vehicles providing local services, could be reflected in a single proposal for application across Great Britain. This would provide consistency for operators and passengers, whilst still enabling us to reflect differences where they were identified.

AIR17: Response summary

Do you agree that the Accessible Information Regulations should apply consistently across England, Scotland and Wales?

Total percentage (%) responses

• Yes: 93%

• No: 2%

• Don’t know or no response: 5%

Number of responses by type of responder

Respondents	Yes (number responding)	No (number responding)
Operators	16	0
Passengers	45	2
Local authority	23	0
Other	10	0

Response analysis

For this question, over 90% of respondents agreed that the Accessible Information Regulations should apply consistently across England, Scotland, and Wales.

Passenger experience

Consistency of experience was cited as the main reason for the view that the regulations should apply across England, Scotland, and Wales. Cross-border travel was also raised by many respondents.

Implementation practicality

A limited number of respondents, while agreeing with the overarching principle of consistency, commented that in certain cases, particularly rural areas, exceptions should be considered.

AIR17: Conclusions and next steps

In this consultation question we asked respondents whether they supported the Accessible Information Regulations being applicable across the three nations of England, Scotland, and Wales. An overwhelming majority (90%) agreed with the sentiment, stating there needs to be a consistent standard for passenger travel across Great Britain. A few supporting respondents raised the possibility for certain exceptions to cover extreme local cases of rurality which could affect operators’ ability to implement the regulations within the expected timeframe and could potentially compromise their provision of local services. Nevertheless, we remain of the stance that the Regulations should apply consistently across Great Britain. Whilst we understand there could be potential cases in remote areas where it may not be possible for operators to implement the regulations at pace, we remain of our view, as mentioned in previous segments, that we will provide financial support via the accessible information grant and guidance to small operators to mitigate the disproportionate impact on their services during the implementation of regulations.

Conclusion

Core proposal

Overall, the range of answers provided by respondents has provided evidence that the Regulations must balance the needs of passengers with the local service sector. The need for onboard information was identified via the steer from responses who supported our proposal to use the legislative powers available to require the provision audible and visible information onboard local services in Great Britain. We will write the Regulations to provide operators with both certainty and flexibility on what to deliver.

Technology

We recognise that we will need to relax our technological neutral approach to allow the regulations and guidance to provide consistent and clear information for stakeholders.

Whilst stakeholders supported the use of a ‘specimen person’, the detailed feedback we received implied there is a risk of the accessible information not being beneficial to disabled passengers. With this mind, we have changed the focus of the quality of information provision so that it is directed towards passengers overall, rather than a single passenger. We will also require that the provision of such information sits within parameters, such as minimum text size and decibel count to create both consistency of the quality of information whilst allowing operators flexibility with systems which work for them. Furthermore, we will write in the regulations that audible information is made available via induction loops to passengers seated in all priority seating and in the wheelchair space, as we remain of the view that this information is key for many passengers to benefit from accessible information.

We will use the guidance to focus on how operators can use advertisements effectively without compromising the quality and benefits of the required provisions of audible and visible information.

Implementation

Several years have passed since we consulted on the Accessible Information Regulations. Covid-19 has impacted the industry in the short and medium term, with potential long-term impacts on overall patronage levels. However, the provision of accessible information applied consistently across the country still remains important to enable people to confidently access the transport network, and thereby supporting the country’s economic growth. As such, we have amended the implementation timescales to reflect the time that has passed since we consulted, but still mindful of the importance of providing accessible information for passengers in a timely manner. There will be three implementation timescales, based on the age of a vehicle. The first of these timescales will come into effect one year following the intended commencement of the regulations, providing operators with time to review those in scope and to make any necessary changes to comply. The following two timescales will apply for each year following, until I October 2026 when all applicable vehicles will need to comply by. We have also decided not to provide separate implementation timescales for smaller operators, as the impact of the £4.65 million accessible information grant intends to support those operators in purchasing equipment to comply with the regulations.

Exemptions

Our intention has been to ensure the proposed regulations are implemented without harming the very industry we seek to enhance, and we recognise specific services should not need to comply with the regulations.

It is clear from the responses that many support our proposals that vehicles which carry fewer than seventeen passengers, tour services as defined by PSVAR, and heritage vehicles should be exempt from the proposed requirements. After being informed by our respondents about their views on exempting services which operate under Section 19 and 22 permits, we will focus on removing the exemption and require new vehicles which operate under Section 22 permits from 1 October 2024 to comply with the regulations. We will also provide an exemption for vehicles which are primarily long-distance, but which have an element of their route which is registered as a local service, as identified as part of our stakeholder engagement whilst developing the regulations. Additionally, we will apply an eight-year exemption from the technical, diversion, and hail and ride requirements for vehicles which already provide a certain standard of audible-visible information onboard. However, these vehicles will be subject to all other requirements from the date of commencement.

Guidance, enforcement and application

Responses highlighted the importance of clear, concise, and detailed information in the guidance. Furthermore, we will use the guidance to provide detail on how the enforcement principles and procedures will be carried out by the Traffic Commissioners and Bus Users UK, and how this will help passengers understand how to report non-compliance and help operators understand the consequences of deliberately running services using non-compliant vehicles.

With the large number of respondents supporting the application of the regulations across Great Britain, we will continue to engage with representatives in the Scottish and Welsh governments during the development and implementation of the Regulations. Furthermore, the department will continue to work with the bus and coach industry, local transport bodies, organisations representing disabled people, and other stakeholders during the next steps of writing and implementing the regulations.