PSVAR Schedule 1 Compliance certificates for National Express coaches

Vehicle Certification Agency did not have the information requested.

Dear Vehicle Certification Agency,

I've been referred to yourselves as potentially holding information that the DVSA were unable to provide in response to this Freedom of Information Request:

https://www.whatdotheyknow.com/request/p...

I'm therefore asking you for substantially the same information.

1) Please supply, or tell me where I can access, the PSVAR Schedule 1 type compliance certificates for coaches in current use by National Express and its franchisees. I particularly would like to see the compliance certificate for their vehicle in most common use, the Caetano Levante, but others are also of interest.

2) Regarding compliance with PSVAR Schedule 1 s3(2) relating to wheelchair spaces:

"One or more seats which are capable of being tipped, folded or otherwise moved may lie within the volume specified in sub-paragraph (1)(a) or within the gangway specified in paragraph 7 provided that the seat is capable of being easily moved out of the volume or out of the gangway. In the case of a single-deck or double-deck coach, this may include a seat which may be quickly dismantled or removed provided that the seat can be safely stowed."

a) Please can you provide any information which gives more depth as to what is required to comply with this regulation? I am particularly interested with the phrase "provided that the seat is capable of being easily moved out of the volume". How is "easily" defined when you are considering compliance?

b) I am looking for information about National Express coaches' compliance with that requirement. Their coaches, including Caetano Levantes and other models, use the "Magic Seat" system that requires removal of a seat and alteration of another in order for a wheelchair user to occupy the space.

The Conduct Regulations require bus drivers to provide wheelchair users access to Schedule 1 vehicle wheelchair spaces irrespective of whether there are seats in the space or not (provided the space isn't already occupied by a wheelchair user, or by passengers or their effects if said passengers cannot readily and easily move to another part of the vehicle, and provided the wheelchair is of a size and condition that is safe to carry.) But National Express have a policy of only accepting wheelchair users for travel where they have booked 36 hours in advance, because the seats have to be removed by engineers in advance of the journey.

Take, for example, this incident:

https://www.youtube.com/watch?v=viq9ClAd...

The driver said: "we're supposed to have 24 hours notice." "It's going to take me at least half an hour to take the seats out." "You see, what it is, what it is, if you give 24 hours notice the mechanics take the seats out." "There's no problem, but give us 24 hours notice, the mechanics take the front seats out. It's not a simple job."

I find it difficult to understand how a wheelchair space which has seats in it which require half an hour to remove, whose seats are only removed by a mechanic, and therefore require 24 hours notice of a wheelchair user's arrival in order to afford access to the wheelchair space, can be said to comply with the Schedule 1 requirement "provided that the seat is capable of being easily moved".

Please provide recorded information that demonstrates how the DVSA considered this obligation when undertaking the type approval of coaches containing National Express's "Magic Seat" (including the Caetano Levante), what factors they considered and how they reached the decision that it is compliant.

If any of that is unclear, you don't hold the information or you are considering using an exemption, please provide me with advice and assistance in formulating a FOI request that is likely to provide me with information in this area which I am likely to find useful or relevant, under your obligation set out in S16 of the Act.

Thank you

Yours faithfully,

Doug Paulley

VCA Enquiries, Vehicle Certification Agency

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VCA

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VCA Ref: EMP426778

 

Dear Mr Paulley

 

Thank you again for your request received by VCA on 04/04/2018.  VCA's
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VCA FOI Team  

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--------------------------------------------------------------------------

From: Doug Paulley <[FOI #475207 email]>
Sent: 04 April 2018 14:30:05
To: VCA Enquiries
Subject: Freedom of Information request - PSVAR Schedule 1 Compliance
certificates for National Express coaches
 
Dear Vehicle Certification Agency,

I've been referred to yourselves as potentially holding information that
the DVSA were unable to provide in response to this Freedom of Information
Request:

[6]https://www.whatdotheyknow.com/request/p...

I'm therefore asking you for substantially the same information.

1) Please supply, or tell me where I can access, the PSVAR Schedule 1 type
compliance certificates for coaches in current use by National Express and
its franchisees. I particularly would like to see the compliance
certificate for their vehicle in most common use, the Caetano Levante, but
others are also of interest.

2) Regarding compliance with PSVAR Schedule 1 s3(2) relating to wheelchair
spaces:

"One or more seats which are capable of being tipped, folded or otherwise
moved may lie within the volume specified in sub-paragraph (1)(a) or
within the gangway specified in paragraph 7 provided that the seat is
capable of being easily moved out of the volume or out of the gangway. In
the case of a single-deck or double-deck coach, this may include a seat
which may be quickly dismantled or removed provided that the seat can be
safely stowed."

a) Please can you provide any information which gives more depth as to
what is required to comply with this regulation? I am particularly
interested with the phrase "provided that the seat is capable of being
easily moved out of the volume". How is "easily" defined when you are
considering compliance?

b) I am looking for information about National Express coaches' compliance
with that requirement. Their coaches, including Caetano Levantes and other
models, use the "Magic Seat" system that requires removal of a seat and
alteration of another in order for a wheelchair user to occupy the space.

The Conduct Regulations require bus drivers to provide wheelchair users
access to Schedule 1 vehicle wheelchair spaces irrespective of whether
there are seats in the space or not (provided the space isn't already
occupied by a wheelchair user, or by passengers or their effects if said
passengers cannot readily and easily move to another part of the vehicle,
and provided the wheelchair is of a size and condition that is safe to
carry.) But National Express have a policy of only accepting wheelchair
users for travel where they have booked 36 hours in advance, because the
seats have to be removed by engineers in advance of the journey.

Take, for example, this incident:

[7]https://www.youtube.com/watch?v=viq9ClAd...

The driver said: "we're supposed to have 24 hours notice." "It's going to
take me at least half an hour to take the seats out." "You see, what it
is, what it is, if you give 24 hours notice the mechanics take the seats
out." "There's no problem, but give us 24 hours notice, the mechanics take
the front seats out. It's not a simple job."

I find it difficult to understand how a wheelchair space which has seats
in it which require half an hour to remove, whose seats are only removed
by a mechanic, and therefore require 24 hours notice of a wheelchair
user's arrival in order to afford access to the wheelchair space, can be
said to comply with the Schedule 1 requirement "provided that the seat is
capable of being easily moved".

Please provide recorded information that demonstrates how the DVSA
considered this obligation when undertaking the type approval of coaches
containing National Express's "Magic Seat" (including the Caetano
Levante), what factors they considered and how they reached the decision
that it is compliant.

If any of that is unclear, you don't hold the information or you are
considering using an exemption, please provide me with advice and
assistance in formulating a FOI request that is likely to provide me with
information in this area which I am likely to find useful or relevant,
under your obligation set out in S16 of the Act.

Thank you

Yours faithfully,

Doug Paulley

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