Written evidence submitted by FirstGroup plc (ATL0050)

About FirstGroup

  1. FirstGroup plc is one of the UK’s leading private sector operators of public transport, employing more than 30,000 people across the country, from Cornwall to Aberdeen, Holyhead to Hull.
  2. We run a fifth of all local bus services in the UK outside of London, working in partnership with local authorities to serve 40 of our largest towns and cities. We also have the largest rail network in the country, with many years of experience operating all types of passenger rail. We run four Government-contracted operations and two open access routes – Lumo and Hull Trains.
  3. We are focused on providing services that have innovation, ease, convenience, and sustainability at their core, to have more people than ever travelling on our services and taking cars off the road. A key part of this commitment is to improve accessibility, and we are making every effort to support customers with disabilities or restricted mobility.
  4. We work with both national and local disability groups and continue to invest in making our services more accessible. From enhanced employee training to more accessible vehicles and technology enhancements, we want to ensure that our services support accessibility and inclusion, and accommodate the needs of all customers.
  5. Should it be of interest, we would be delighted to discuss our submission with the Committee in greater detail.

Our approach to accessibility

  1. We are committed to working alongside government to support and implement the National Disability Strategy and make it easier and more comfortable for disabled passengers to travel on our services.
  2. Below, we set out in more detail some of the actions we have taken to date to increase accessibility for both our rail and bus services.

First Rail

  1. In line with guidance from the Department for Transport (DfT), each of our Train Operating Companies (TOC) have issued accessible travel policies (ATPs), setting out the level of service that disabled passengers can expect when travelling on our routes and using our station facilities. This includes access to passenger assistance, alternative accessible travel arrangements, ticketing and fares information, and passenger information. These are approved and monitored by the Office of Rail and Road (ORR), and include information on passenger assistance, alternative accessible transport and tickets and fares.
  2. All our TOCs have their own formal forum or panel which they use to continually engage with our passengers with disabilities or reduced mobility. These groups have been integral in developing respective Disability and Equality Awareness training packages, finalising our Accessible Travel Policies, and other such projects.
  3. For instance, at South Western Railway (SWR), our Accessibility and Inclusion Forum was the driving force behind the updated feel and narrative of our updated Disability and Equality Awareness training packages (updated in Autumn 2022 from an initial launch in January 2021.) The forum members used their lived experience of disability and travel on SWR to inform the TOC where colleagues needed to improve their awareness, but also where they were doing things well. They also shared best practice from outside the industry. The updated package, especially the refresher package, feels more like a conversation between the disabled customer and SWR colleagues taking part in the eLearning and safe-space discussions.

 

  1. Each TOC also has a person responsible for accessibility at both a board and operational level. We are actively making investments across our rail operations, going beyond legal requirements to improve the experience for disabled passengers, including:

11.1.                  This month TransPennine Express (TPE) launched two innovations to support those with increased needs. A pre-departure tool – My Station View – enables passengers to take a virtual tour of 19 managed stations and train interiors to identify priority seating and facilities in advance; while GoodMaps Explore provides accurate navigation support within stations for customers that are blind or visually impaired. Last year, TPE also invested over £100,000 to enhance the accessibility of its stations, fitting electronic devices into toilets at 16 stations to provide audio descriptions and map out features, and installing braille handrails at Scunthorpe and Grimsby stations.

11.2.                  Avanti West Coast provides ‘Travel Companions’, connecting disabled customers with accessible travel experts to receive instant help during journeys. Passengers are able to contact support via WhatsApp whilst travelling on the West Coast Main Line, enabling a member of the team to check in on their needs and organise assistance from support staff, if required.

11.3.                  SWR is trialling Artificial Intelligence at London Waterloo to provide train information using British Sign Language to deaf passengers and those with hearing loss. Announcements are displayed on digital totem screens, with the success of the trial to be evaluated after six months. This builds on a three-month trial of cutting-edge Near Field technology at two stations to provide audio directions to passengers with sight-loss, including directions to Assisted Boarding Points.

11.4.                  Great Western Railway (GWR) was shortlisted the National Rail Award for Customer Service Excellence for its installation of technology to provide audio descriptions of facilities at 15 stations. GWR is also embarking on a programme of station upgrades to increase accessibility across its network. This includes installing new accessible toilets and washrooms and transforming the design of concourses.

  1. All our TOCs have complaints and redress processes in place, and engage with Transport Focus to ensure that we are responding to customer feedback and meeting our passengers’ needs.
  2. We look forward to further engagement on accessibility with government, industry and passengers as part of railways reform set out in the Plan for Rail.

First Bus

  1. First Bus is fully compliant with the requirements of the Public Service Vehicles Accessibility Regulations (PSVAR) in all the towns and cities we serve, ensuring that our buses contain priority seating, lifts and ramps for wheelchair users, and dedicated spaces for wheelchairs and handholds.
  2. Many of our buses already provide audio and visual information on different aspects of journeys, including the direction of travel, next stops, diversions and connections to other services. We have had Bus Passenger Charters in place for many years in some of our operating areas and are fully engaged with local authorities to implement these across all Bus Service Improvement Plans and Enhanced Partnerships. We have worked with local authorities and the DfT to lobby for improvements in bus stop accessibility and routes to bus stops which are accessible to all.
  3. We are proactively taking steps to increase accessibility across our operations:

16.1.                  Each of our 10,500 drivers is receiving training so that they better understand the needs of customers with disabilities, including hidden disabilities, reduced mobility and sensory impairment, and their particular needs to help them use the bus. In 2014, we became the first bus operator to sign the RNIB's bus charter.

16.2.                  Working with the Alzheimer's Society we have implemented a module to its driver training programme so that front-line staff can provide assistance, if needed, to customers who have dementia.

16.3.                  We have worked with Disability Action Alliance and Age UK and introduced 'Extra Help to Travel Cards', which discreetly allow customers to let drivers know if they need extra help or assistance on their journeys. Such has been their success that these Cards have been adopted by the wider bus industry.

16.4.                  We have worked with other operators and the Confederation of Passenger Transport to develop and implement the Mobility Scooter Code of Conduct, which allows customers to bring mobility scooters of appropriate size onto buses once they have completed a brief evaluation of their control of the device. Passing the evaluation provides the customer with a card which is accepted by all major UK bus operators and allows them to bring the scooter on board.

Our experience of the legislative and policy framework

  1. Across both our rail and bus operations, we believe that current regulations and legislation should be strengthened to provide a minimum level of service, rather than being perceived as gold standard, in order to align with customer expectations.

First Rail

Rolling stock

  1. Accessibility requirements for trains in service, both refurbished and new rolling stock, are set out in the Rail Vehicle Accessibility (Non-Interoperable Rail System) 2010, which provided a minimum standard framework for train operators to make their trains more accessible to people with reduced mobility by the end of the decade. However, these regulations have not been updated since then, and can fall below customer expectations.
  2. For example, while there are legal requirements for wheelchair spaces on trains, there is no specification for other mobility aids (or prams / pushchairs) , with each operator simply having to outline their approach within ATPs, leading to inconsistency for passengers who are taking journeys across more than one operator. We would welcome greater guidance from the Department as part of its planned rail accessibility strategy on the allocation of space for mobility scooters on board services.
  3. Moreover, now that all train operators, including ourselves, have ensured that trains in service meet legal accessibility requirements, we would welcome a review of current accessibility requirements for rail. While regulations have undoubtedly helped to drive up standards across the industry, there are few incentives for operators to go beyond minimum thresholds. As government continues to develop its plans for rail reform, we urge ministers and officials to consider how it can further improve accessibility on trains, including an industry-roadmap for driving up standards.
  4. We welcomed the extension from DfT to comply with changes to PSVAR for rail replacement bus services. For long-distance journeys, we remain reliant on the procurement of coaches from SMEs, many of whom remain uncompliant with the scope of regulations. As such, we would welcome greater guidance from government on how it plans to improve standards in the industry.

Stations

  1. We welcome government’s pledge in the National Disability Strategy to conduct an audit of accessibility at rail stations, which builds on our own work to improve accessibility across our network. For example, when designing new stations, we consult on accessibility requirements as part of feasibility studies and planning applications to ensure that we meet the needs of disabled passengers. During the development of the new Reading Green Park station, GWR has engaged closely with disability groups, charities such as Guide Dogs, and customers to ensure that there are fully accessible platforms; while TPE is working closely with partners to maximise accessibility at the new White Rose Station, currently in construction.
  2. We are also taking steps to improve accessibility at existing stations, working in partnership with government and Network Rail. For example, Avanti has recently introduced tactile paving as part of its work to refurbish Carlisle station; while South Western Railway has installed step-free access at stations including Liphook, Barnes, Wandsworth Town and Walton-on-Thames.
  3. However, to support further enhancements, we urge government to reform the Access for All scheme, with data showing that only 20% of stations in the UK incorporate new-to-build standards[1]. Currently, the criteria for applications are too restrictive, and more applicable to urban, rather than rural, settings. As part of its development of an accessibility plan for rail, we support the recommendation that government produces a strategic plan for upgrading stations, set out in Disabled Persons Transport Advisory Committee’s report last year.
  4. Government should also reconsider funding allocations that have already been made given current levels of inflation, with the increased costs of materials placing strain on projects in development or construction. We urge DfT to raise this with HM Treasury as priority.
  5. We look forward to further engagement with government on station design and improvements, including the through the forthcoming consultation that was announced in the Plan for Rail.

Workforce             

  1. In line with ATPs across our organisation, all our passenger-facing staff have undertaken disability awareness training. We have developed courses, used as part of staff inductions as well as refresher training for existing staff.
  2. All our TOCs are signatories to the Sunflower Lanyard scheme, with our staff trained to help those with hidden disabilities and provide additional support during journeys if required. We also offer travel assistance cards, which can be shown to staff.

First Bus

Vehicle fleets

  1. First Bus complies with the PSVAR 2000, ensuring that all vehicles designed to carry over 22 passengers in our operational fleets provide spaces for wheelchairs; incorporate priority seating; and provide handrails, ramps or lifts, and audio and visible signals to notify the driver that they wish to stop a vehicle.
  2. We note the government’s observations in the Inclusive Transport Strategy, where passengers have referred to outdated regulations pertaining to wheelchair spaces. While there is no legal requirement for the carriage of mobility scooters on local services, we have worked with other operators and the Confederation of Passenger Transport to develop an industry code of conduct to make this as simple as possible for customers. Where possible, we have made investments to improve the experience for passengers, including incorporating space for multiple wheelchairs on our latest Bristol fleet, and working with Wrightbus to redesign the shape of the hand-pole in priority spaces to make it easier for disabled passengers to reach and use.
  3. However, as set out in the National Bus Strategy and National Disability Strategy, we urge government to bring forward its review of PSVAR and engage with bus operators, industry bodies and charities on the introduction of new measures and ensure that regulations remain up to date and take account of the practicalities of bus and coach design.
  4. We are also committed to increasing our provision of on-board real time audio and visual information for blind and visually impaired passengers. We have been working with government on the introduction of regulations setting out mandatory requirements for audio-visual requirements following the passage of the Bus Services Act 2017. We urge government to bring forward these regulations and associated guidance as soon as possible in order to drive up standards across the industry and support bus reform following the introduction of Bus Service Improvement Plans and Enhanced Partnerships.

Infrastructure and digital technology

  1. We are committed to working with all our local transport authority partners to bring forward accessibility enhancements to bus stops and stations, and improved accessible access routes to these, as set out in the National Bus Strategy and the government’s vision for Bus Service Improvement Plans (BSIPs). This includes ensuring that pavements are level and provide easy boarding onto buses, installing relevant audio-visual information and information about bus stops and stations in journey planners and printed material, and setting out clear information on accessibility as part of Bus Passenger Charters.
  2. Several of our partner local authorities did receive central government funding to implement their BSIPs, however several bids were unsuccessful. We would welcome guidance from government on what support will be provided to local authorities that have not received funding; as well as the provision of a dedicated funding pots, similar to the Access to All scheme for rail, to enable local authorities to improve access routes to bus stations and stops.
  3. First Bus offers information on all bus routes to enable passengers to plan their journeys on advance, including maps of routes, departure times, real time travel updates and directions to bus stops. Both our website and mobile application incorporate live journey planners and the option to buy tickets in advance, helping to alleviate stress.
  4. We have also worked with the DfT on the development of its Bus Open Data Service (BODS) which seeks to make service, fare and real time operational data available to all providers and developers of passenger information and journey planning systems. Our ability to run our digital services and provide real-time passenger information, and the development of BODS, are contingent on the accuracy and maintenance of third party databases including the National Public Transport Access Nodes (NaPTAN) database of transport access points, as well as reuyet uncatalogued inventories of locality information. We have welcomed steps taken by government to review the structure of the database in recent years to increase their coverage of accessibility data, but would welcome greater clarity on work to improve data quality and ensure geospatial consistency.

Workforce

  1. In line with legal requirements, we ensure that all our bus drivers receive disability awareness training, which has been designed in partnership with local and national groups representing the needs and concerns of people with a wide range of disabilities.
  2. As an example, we were the first bus operator to sign the RNIB’s charter. This means that if a blind or visual impaired passenger is waiting at a bus stop the driver will stop, unless they have clearly signalled that they do not want the bus to stop, and advise which route the vehicle is operating. Even if the bus is full, the driver will stop and advise that this is the case, giving an indication of how long passengers will have to wait for the next service. All assistances dogs are also able to travel for free on our services.
  3. Our drivers are also trained to assist passengers that use our dedicated Extra Help to Travel cards, and will ensure that dedicated, tailored support is offered and provided. For wheelchair users, drivers are instructed to support boarding and alighting using access ramps (or where appropriate, lifts), to provide assistance as required, and to ensure that dedicated wheelchair areas are made available to those that need them.
  4. We would, however, welcome efforts from government to ensure that these legal requirements, and best practice standards, are adopted across the industry.
  5. We also still have a shortage of bus drivers across the industry. We urge ministers to bring forward a new campaign to encourage more people to enter the industry. This will ensure that we are able to operate our services in accordance with the registered timetables across the country, and therefore offer necessary support to all our customers, including those with disabilities.

 

March 2023

Endnote

[1] https://www.gov.uk/government/publications/dptac-reference-frame-working-towards-a-fully-accessible-railway/dptac-reference-frame-working-towards-a-fully-accessible-railway#timescales-involved