Accessibility to coaches
The coach market in Germany has developed extremely rapidly since its liberalization on January 1, 2013. The amendment of the Passenger Transportation Act (PBefG) made it important for all stakeholders to give people with restricted mobility access to this new means of transport. Paragraph 4 of the Equality for the Disabled Act (BGG) describes what accessibility means: “Means of transport … are accessible … if they can be accessed and used by people with disabilities in the generally usual way, without particular difficulty and in all cases without external assistance.” Paragraph 8 specifies: “…Means of public transport shall be made accessible in accordance with the relevant legal regulations issued by the Federal Government.” This means all means of transport must be able to be used by people with disabilities. They are not allowed to be disadvantaged compared to other passengers. Paragraph 42b, Technical requirements, observes: “…Motor coaches used for long-distance passenger transport shall meet the requirements of Appendix VII to Directive 2001/85/EC of the European Parliament… and be equipped with at least two places for wheelchair users.” Furthermore, paragraph 62 states: “…this applies from January 1, 2016 for motor coaches first registered for use in transportation and to all motor coaches after December 31, 2019.”
This means, observing the transitional provisions, safe transport of at least two wheelchair passengers will have to be possible in future in every coach. As a result, coach operators and manufacturers are faced with the question of how to implement these requirements. The reference to Appendix VII of the directive relating to special provisions for vehicles used for the carriage of passengers comprising more than eight seats in addition to the driver’s seat (2001/85/EC) in the Passenger Transportation Act points the way ahead.
This directive was superseded by implementing the General Safety Regulation (EC/661/2009) in November 2014, and will be replaced by UN regulation 107 on uniform provisions concerning the approval of category M2 or M3 vehicles with regard to their general construction. Some time ago, UN R107 was supplemented by Appendix 8 containing regulations on technical equipment for passengers with restricted mobility. This appendix forms the basis for the type approval of designs for installations in coaches intended to implement the requirements of the Passenger Transportation Act. In contrast to the European Regulation, UN R107 has been updated over the last ten years and is internationally recognized in all European countries, in Russia, Belarus, Kazakhstan, Azerbaijan, Tunisia, Egypt, Malaysia and Turkey. Mutual recognition of type-approved coaches according to UN R107 creates a secure legal basis for selling and registering these vehicles in the signatory states. As a result, in the type approval coach manufacturers can refer to compliance with regulations that are the same everywhere. As far as the operators of coaches are concerned, this offers the advantage that they can purchase vehicles from the various countries and use them on the roads without having to make compromises with regard to the level of safety.
Regulation 107 defines various terms (wheelchair user, passenger with restricted mobility, accompanying person, priority seat, access assistance, lowering device, lifting device, ramp, etc.) and creates the framework for an identical basic understanding in the use of this terminology. Appendix 8 describes detailed design principles for transporting people with restricted mobility. As a rule, wheelchairs are secured using belts, which means the inspection regulations also relate to the belts and belt anchoring points. Many wheelchairs are individually customized, meaning that it is not always possible to assume that standard interfaces will be available for attaching the vehicle belts. Standardization of the wheelchair interface would be desirable in order to allow the accompanying personnel or driver to securely attach the wheelchair using the vehicle restraint systems.
Also, the wheelchair user should know to what extent their wheelchair is suitable for carriage in means of transport. At the same time, deliberate attention should be paid to the situation that significant forces are applied to the wheelchair and the fastening mechanisms in the event of an accident, and that structural failure of the wheelchair must be avoided. As a result, uniform identification of wheelchairs is expressly to be welcomed.
There are various access assistance functions available for allowing wheelchair users to be transported on coaches. In principle, three different design possibilities can be implemented that guarantee safe entry and alighting on their own or in combination with one another: the lowering device, the ramp and the lifting device. The lowering device allows the entire coach to be lowered at one side – this function is encountered in urban buses in particular. Together with a wheelchair ramp, it permits barrier-free access at bus stops with a curb, assuming the vehicle is a low-floor bus.
As a rule, high-decker or double-decker coaches are used for long-distance transport. Access to the high-decker coach must be provided using a lifting device. In the double-decker coach, only a ramp is required because of the low-floor lower deck. Operating the ramp is straightforward and it can be used in compliance with the maximum permitted gradient (maximum 12 percent if there is a curb or 36 percent without one). The lifting device used in high-decker coaches makes it possible to lift the wheelchair to the level of the passenger compartment. Generally speaking, entry is by a separate door. The lifting device is securely mounted on the vehicle and can be stored in the lower deck (engine or luggage compartment). Both devices are operated remotely, and the person with restricted mobility can communicate with the driver by means of communication facilities on the outside of the coach. During normal operation, it can be assumed that the coach driver will be responsible for issuing the luggage, which means he/she can receive the wheelchair user outside the coach.
As well as transporting people in a wheelchair, there are further features that are described by the accessibility guidelines. These include compliance with requirements on transporting people with impaired vision. Regulation 107 indicates design measures for guiding these passengers to their seat. For example, grab rods and door operating devices should be in a contrasting color. Furthermore, coach manufacturers can identify seats using braille or embossed lettering. Experience gained during the coming years will indicate whether the content of UN R107 can be implemented practically and to what extent possible changes will need to be discussed internationally.
Under the direction of Bundesverband Selbsthilfe Körperbehinderter e.V. (BSK), an organization in Germany focusing on self-help for people with physical disabilities, a steering group was formed and prepared common specifications for accessible coach transport. Various operator, manufacturer and disabled persons’ associations joined the steering group. The specifications are intended to take account of technical feasibility aspects as well as the interests of the driver and the passenger with restricted mobility. The VDA actively supported this work by providing its technical expertise in the design of coaches.
Another research project on this subject was launched by the German Federal Highway Research Institute (BASt). The project entitled “Accessibility in coaches” was started at the end of 2013 and had a two-part structure. As a first step, by mid-2014, the aspect of accessibility in connection with the use of coaches for long-distance passenger transport was investigated in more detail. The objective was to analyze the expectations of all stakeholders (vehicle manufacturers, operators and passengers), and to produce a forecast for future use. A kick-off workshop was held in early 2014 for this purpose. In the second part of the project, the actual status of technical systems was presented, recommendations for measures to shape the environment for transporting people with restricted mobility were worked out and suggestions were described with a view to possible adaptations to regulations and/or standards. The project was concluded mid-2015.