ASLEF Consultation Response - Department for Transport - Design standard for accessible railway stations: a code of practice
The Department for Transport consulted on the code of practice on design standards for accessible railway stations between 23 August 2023 and 1 December 2023. The consultation wanted to investigate areas of the code of practice which could be updated to improve accessibility at railway stations.
Below is ASLEF's response:
ASLEF Consultation Response – Department for Transport – Design standards for accessible railway stations: a code of practice
- The Associated Society of Locomotive Engineers and Firemen (ASLEF) is the UK’s largest train driver’s union representing just under 22,000 members in train operating companies, freight companies as well as London Underground and light rail systems.
- We have long campaigned for greater accessibility across the railway raising it as apart of our Invest in Rail campaign and in 2021 highlighting the work that can be done in Scotland to improve accessibility in the ‘A Vision for Scotland’s Railways’ report. We have also raised the need for accessibility improvements across the union movement via the TUC, STUC and WTUC and continue to highlight the improvement needs where appropriate in evidence submissions and consultations responses.
- We welcome the Department for Transport reviewing the code of practice on design standards for accessible railway stations as we believe there are some areas that could benefit from being updated. We will highlight some of the questions where we have specific input on the code of practice in its current state.
3 - In your experience, are current standards and guidance relating to lift provisions suitable or not suitable for current railway station use?
No, they are not suitable
- Whilst the technical guidance and standards relating to lift provisions are suitable, currently there is a gap which allows new stations to be built where the lifts meet the current standards and guidance but there is a lack of appropriate guidance around staffing such stations. Reston station (opened 2022) is a good example of this, Platform 2 is only fully accessible via the lift / foot bridge, if a lift is broken then passengers that require services from platform 2 will have to head to another station.
- We believe that greater guidance should be provided around steps to be taken when a lift fault/failure is present, inclusive of the use of present staff to help rectify the problem and assist passengers.
- Currently there is guidance around repairing induction loops under L2 g. which stipulates a repair must be made within 48 hours of notification of failure. To improve accessibility and the provision of lifts, similar guidance could be added for lifts to require their repair in a timely manner due to the impacts a broken lift can have on accessibility such as rendering half of a new station inaccessible.
- With regards to current stations being renewed or upgraded we have concerns that F1. 8 enables station operators to avoid making their stations truly accessible if another station within 50 km on the same route provides a fully compliant obstacle-free route. We do not think it is acceptable to allow operators to avoid making their stations fully step free and as such forcing disabled passengers to use different stations if their desired station does not have lifts or ramps. This standard allows operators to force a disabled passenger to use a station up to 31 miles away if the volume of passengers isn’t deemed high enough when carrying out renewals or upgrades. We hope that the DfT’s Access for All work and the ongoing review of step free access across the network will look to address this to avoid treating disabled passengers as an inconvenience.
10 - Do you think that the current standards and guidance provide a sufficient number of accessible car parking spaces at railway stations?
- Whilst the guidance states a minimum number of 1 space for each employee who is disabled plus 5 percent of the total capacity for disabled passengers with a further 5 percent to be large spaces allowing for the expansion of disabled spaces if required, we hold concerns around the sale of car parks or the use of car parks on private land not falling under the same obligations as a public car park, which all station car parks should be.
- We also hold concerns that a long lease on a car park owned by a third party could be prohibitive of it meeting the standards and guidance that are expected of a car park serving a railway station. Any future long leases could also result in the car park not meeting the standards and guidance if these are to be updated at a future point, this could leave the operator having to wait until the next review of their contract, delaying the ability for the operator to ensure that there are the appropriate number and standard of accessible car parking spaces at their station.
- Guidance C.1.a states that when a third party operates the car park, "...the station operator should ensure that conditions are introduced at the next review of the contract to require compliance with the standards in the Code." we believe there needs to be greater emphasis on the requirement for all car parks used by the station operators, operated by third parties or directly, to meet the requirements and recommendations. A change of word from 'should' to 'must' would add greater emphasis to the operator's duty to provide appropriate accessible parking bays as the provider of a service.
11 - Do you think that there should or should not be a mandatory standard relating to the provision of accessible electric vehicle charging bays?
Yes, there should be
- The shift from traditional combustion engine emitting greenhouse gasses to hybrid and now fully electric vehicles has been accelerating as car makers and government's begin to grasp the seriousness of the climate crisis. We currently have over 920,000 fully electric vehicles registered in the UK with a further 560,000 plug in hybrids and this number will only increase as manufacturers begin to move towards only hybrid and fully electric vehicles.
- As more and more car drivers will be using electric vehicles the guidance should be updated to reflect this to avoid the accessible spaces being more favourable towards traditional combustion engine / hybrid cars. The provision of an accessible electric vehicle charging bay should receive a mandatory standard to ensure that the spaces provided are appropriate and meet the needs of the users.
- It is important that disabled people aren't ignored with the increase of electric vehicle charging bays at car parks and railway stations. As disabled drivers can utilise schemes such as Motability which entitles them to a more affordable lease on a new car, the majority of these cars will be new and with more electric vehicles coming to the market, these vehicles will likely be electric. It would therefore be appropriate for the car parks at railway stations to be mandated to provide accessible electric vehicle charging bays.
12 - Are the current standards and guidance in this section appropriate or not appropriate for current use (including the provision of changing places facilities)?
Some are appropriate, some are not appropriate
- Currently there are concerns around the availability and access to toilets and changing places facilities across the network, this is in part a reflection of the managed decline on the railways under the watch of consecutive Conservative led governments looking to encourage and facilitate the de-staffing of stations which ultimately has an impact on the availability and access to toilets across the network.
- Alongside appropriately staffing stations, we believe that there is scope for the guidance around toilets to be improved. Whilst the ORR has input into toilet opening hours we believe that the guidance under U3 could be expanded to further encourage the use of the National Key Scheme to increase its use and availability across the network. Further to this there should be greater emphasis on the guidance around the availability of staff to assist with unlocking these toilets if a user does not have a key themselves as ultimately if there was an emergency whilst the disabled person was using the toilet a member of staff would be needed to respond. So whilst we want to see the guidance strengthened to call for an increase of the use of the National Key Scheme, we see this being encouraged alongside an appropriately staffed railway.
16 - Do you think that all footbridges should be:
- Footbridges should be covered where practicable to further protect the access routes from inclement weather, this will ensure that all users of the footbridges including staff will be better protected from varying weather. Covered footbridges also offer greater protection for the track, staff and passengers by putting a barrier in place which further prohibits trespass incidents or the throwing of items from the bridge.
19 - How, in your view, might mobile applications and other digital technology be used to support the passenger travel experience for disabled people (including examples)?
- There is an opportunity for digital technology to assist disabled passengers, we have seen recent initiatives such as the use or virtual reality to create models of trains and stations which passengers can explore so that they can understand where everything is ahead of arriving if they are unfamiliar with a station or train. There is also the potential for augmented reality applications to work within stations to help passengers better understand their surroundings and where they need to go. It would be sensible for such applications to be available in one central app under the umbrella of an at arms length body such as Great British Railways once one is in full existence to ensure that all passengers can easily access the applications and find them easily via the public body overseeing railway operations.
- As ever, we would caution any moves to implement mobile applications or other digital technology to replace a physical presence of a worker or to justify the continuation of a lack of staff. We can see such technologies being delivered in collaboration with the station and on-board staff to assist them in their jobs as well as assisting passengers in their travel experience. Such technologies should be designed and delivered with input from the staff to avoid instances such as what we presently see with ticket scanning where a staff member has to open multiple applications on their device to read the QR codes and smart cards.
77 St John Street