Draft Disabled People's Protection Policies (DPPPs)

prepared during autumn 2002

4. Detailed Arrangements (Section 7 of the Guidance)

On-going requirements

7.1 Operators must give a commitment for the DPPP to be a 'live' document that is seeking continuous improvement to the way services and facilities are delivered to disabled passengers. The DPPP must be reviewed by the operator and submitted to the Authority annually from the date of approval.

4.1 Each operator had a different interpretation of the requirements of this guidance. We would expect a clear statement to continually improve services and facilities available through integrating access for disabled people into the running of the business. We would also expect to see a clear commitment from all operators to submit a reviewed DPPP to the SRA annually.

4.2 The SRA should provide clear guidance of how it will monitor the documents, so that the idea of 'live' documents has some meaning in time for the annual updates. We would hope that this process would allow for some of the improvements mentioned elsewhere in this report.

7.2 Operators must have a strategy for the implementation of plans and policies not currently in place for access and services, using where necessary the guidance on the prioritisation of works at stations (Appendix b). Once the matrices have been completed and the mechanism for allowing operators to bid for money from the 'Access for All Fund' has been agreed, implemented and the operator's proposals have been accepted by the Authority, operators must give committed timescales for works to be completed.

7.3 Operators must give an outline description of any existing plans and any known future plans for stations and/or rolling stock works including how accessibility improvements are being incorporated in them. Examples may include outline proposals for rolling stock refurbishment; the addition of facilities at stations which will improve or enable access for disabled people; plans for new stations or complete refurbishment of existing ones etc.

4.3 There was a disappointing lack of strategies for implementation and description of existing plans with many referring to this being dependent on funding. This was surprising as it enables operators to identify what they can reasonably achieve by certain dates (such as the end of a franchise) and is therefore very relevant to operators with short franchises.

4.4 It is also difficult to assume what funding will be used for if operators are granted more money. We would have expected operators to state what they could achieve in different scenarios.

4.5 In relation to existing plans we would expect operators to give an indication of how these plans and works will be monitored. We recognise that due to the varying number and types of stations operated and types of rolling stock, this will be a more complicated task for some Operators.

4.6 In determining the mechanism for allowing operators to bid for money from the 'Access for All' fund we expect the SRA to state clearly that any works proposals must be include the involvement of a person competent in access issues.

Prior to the journey

7.4 Each operator's revised DPPP must detail the facilities, services and accessibility at all its stations, including the station category as defined by Railtrack. See Appendix A for a list of the minimum information which must be provided. The Authority considers that this matrix will help operators towards fulfilling their responsibilities under Part III of the DDA by enabling them to classify their stations and document their accessibility. It must be noted however that completing the matrix is not comparable to an access audit for the operators' stations, any access audits need to be carried out by access consultants. The final two columns of the matrix are perhaps the most important as they will describe operators' proposed actions to enable disabled people to use all of their services and facilities prior to and after 1 October 2004 (see also Section A4.1 of the code). From this date, if there is a physical feature that makes it impossible or unreasonably difficult for disabled people to use a station, the station operator will have to either remove, or alter this feature or provide a reasonable means of avoiding it. The final column of the matrix (Appendix A) will only need to be filled in when the priorities (see Appendix B) have been agreed with other stakeholders and the Authority.

Examples of this could be - a wheelchair user who cannot currently access the platform(s), or a person with walking difficulties who cannot manage a lot of steps, at the station at the start of their journey; a visually impaired person not having any means of knowing the destination(s) of the train(s) that call at the station. A reasonable adjustment in the short term by the operator could be that the operator provides an alternative means of accessible transport to the nearest accessible station on that persons' desired route. It is not expected that an operator would charge that person any extra for this service than the amount they would have paid from the inaccessible station at the start of the journey. As part of the review of their DPPP operators will be expected to prioritise identified solutions to access at all of their stations. This will also enable them to inform disabled people when an inaccessible facility at a station is likely to be removed or altered at a point in time in the future (subject to appropriate funding).

4.7 We welcome the matrix concept and believe it will help operators meet their duties under Part III of the Disability Discrimination Act, including the final duties which come into force in October 2004.

4.8 We would welcome each Policy including a commitment to utilise a person competent in access issues when conducting access audits, before prioritising any work at stations, and throughout project development. The matrices are not comparable to an access audit and it would be unwise to based future expenditure on them. It is essential money is spent effectively and to national standards in the SRA Code as it will be difficult to justify spending the money twice.

4.9 DPTAC does not have the local knowledge or capacity to comment on every specific Station Matrix. However DPTAC has consulted with the Rail Passenger Committees to ensure that their members undertaking site visits verify information are aware of relevant issues and the intention behind the requirements.

4.10 We are aware that RPCs have had similar problems obtaining matrices for checking and share DPTACs concerns over the process. This is disappointing as working in partnership progress could have been achieved much more effectively.

7.5 A commitment must also be given that this information will also be available on a database and that other operators will be able to access the information on request. Where the database has helplines or other relevant numbers for disabled passengers, a commitment must be given that these are available for access by the National Rail Enquiry Service (NRES), all other licensed operators, and be suitable to be accessed by the Rail Journey Information Service (RJIS), Transport Direct, or any future improved system. A commitment must be given that a specific post will be accountable for updating the information on the database within 24 hours of notification of the problem. It must be stated that all of this information (after the database has been set up) will be available to disabled passengers at the operator's information points or at station ticket offices, by telephone and on the operator's website.

4.11 There seems to be some confusion amongst Operators as to the content and format of information to be made available on the databases.

4.12 DPTAC would expect that SRA, operators and ATOC to work together to ensure a standard format for this information, enabling compatibility between databases, see 7.7 below. We welcome ATOC's work in this area.

4.13 There needs to be greater clarity over which job post is responsible for updating the database. It is not sufficient to refer to a 'member of staff' and this might form part of the objectives of a particular post to enable monitoring of performance.

4.14 As mentioned previously, it is important that information for passengers from this database is given with a health warning as the data has been collected by people who are not always competent in access issues. Inaccurate or misleading information will damage the confidence of travelers and perception of the industry.

4.15 Arriva Trains Northern committed to placing the Station Matrices on their website by the end of 2002 and by 1 October 2004. These specific dates are particularly welcome targets by which the Policy can be monitored.

7.6 A commitment to ensure that the database (currently delivered through the Disabled Persons Reporting System (DPRS)) is correctly updated within 24 hours when facilities such as lifts and toilets at stations are out of order so that passengers who request assistance will know of any limitations to services or facilities. Operators should be able to receive information from disabled passengers about facilities that are not working, this is particularly important where these facilities are at unstaffed or part staffed stations.

4.16 A substantial number of operators failed to include a commitment to update the DPRS within their drafts. Of those who did, a significant number did so with caveats and exclusions such as weekends and no mention of being able to receive updates from disabled people which would prove a both effective updating tool and a good customer liaison exercise.

4.17 This weakness in the system may be due to the lack of a designated person responsible for the task. We feel that this highlights a wider problem with the DPRS whereby the potential to collect useful management information on meeting the needs of disabled passengers is being lost.

4.18 The callback service operated by South Central and Connex enables them to access passengers views and hard data about journeys at very low cost. This can then be fed into the business development to help prioritise the areas for improvement.

7.7 It is recommended that a national database is created that can be used by all parties. If this database is available this would meet the requirements of paragraph 7.6 and in the Authority's opinion would be the ideal solution. However this system is not available to all operators and the Authority will expect a commitment that all operators will be able to input to and access this database before 1 October 2004. The Association of Train Operating Companies (ATOC) has already been working with the operators in compiling a database of station accessibility within phase 2 of the RJIS project. When this work is finished RJIS will provide a comprehensive facility for the whole of the National Rail Network. Once it is fully operational, ATOC plan to make it available to the public through the medium of the National Rail website (http://www.nationalrail.co.uk).

4.19 We understand there has been progress on the development of the ATOC database and are seeking further information. We believe this type of information facility is best managed centrally to cover the entire network with ownership among all those in the industry.

Car Parking

7.8 Operators must detail what enforcement and security measures are in place for monitoring disabled car parking bays within the station lease area including those operated by contractors. A commitment must be given that the usage of disabled car parking bays (where the numbers do not currently comply with Section B3.2 of the code) will be monitored every six months (more frequently if appropriate). Operators must state that the results will be sent to the Authority. This is to make sure that motorists who do not hold disabled parking badges are not using these spaces.

4.20 Details of operators arrangements varied greatly on this issue from daily monitoring and handing out Penalty Charge Notices (PCN) to non-badge holders parked in accessible bays.

4.21 We would expect operators to demonstrate that they have read and adopted the guidance set out in section B3:2 of the Code, outlining practices and policies for the management and monitoring of accessible parking bays in their Policy.

4.22 DPTAC would encourage operators to include a management statement that it should be embedded into policy that relevant employees monitor the parking bays at regular intervals and are empowered to take action where possible.

4.23 We would also encourage the SRA to publish the information it receives so that on-going performance can be monitored. This may help raise the profile among non-badge holders of the need not to park in these spaces.

Disabled Persons Reporting System

7.9 Each operator must have a telephone number to enable disabled people to book assistance. Operators must commit to making these numbers local rate calls from anywhere in the country. Operators must commit to installing minicom facilities where they do not currently exist. Current arrangements are processed using the Disabled Persons Reporting System (DPRS). Operators must commit to ensure that details of the times between which assistance can be provided at stations and on trains will be shown on the DPRS.

4.24 We are aware that most operators do have local rate telephone numbers and Minicom facilities but are disappointed that many have not included this information in their Policies. This is an area where operators could have demonstrated they were generally meeting the Guidance. We would expect to see the inclusion of these details in the final documents.

7.10 It is expected that a commitment will be given that, except where a station has physical constraints which prevents some people with disabilities from being able to use it (e.g. no step-free access), assistance can be arranged through DPRS during the hours that trains are scheduled to serve that station.

4.25 DPTAC found the response to this section very disappointing. Whilst acknowledging that Operators with many small and unstaffed stations may find providing assistance very problematic if on demand, arranged assistance should be possible from on-train staff.

4.26 As a result many operators commit only to a core network and assistance at particular times. There is also an issue in relation to the provision of assistance at stations operated by other operators where no commitments are given. So for example, in some situations operators will take no responsibility for lifts operated by Railtrack.

4.27 We would recommend the industry consider the provision of assistance from the perspective of a passenger trying to complete a journey and devise workable mechanisms that ensure the effective provision of assistance.

7.11 A commitment must also be given that where possible, through the operator's database, DPRS will also be updated with information about facilities on trains that materially affect disabled passengers journeys that are unavailable for a significant period of time.

4.28 DPTAC were concerned by the number of Operators who did not give a clear commitment to update DPRS with the relevant information. The lack of this information may seriously undermine the accuracy and therefore credibility of the DPRS and raises concerns about disabled travelers being unable to travel or being stranded part way through a journey despite advance booking or checking of services and facilities.

4.29 We will be concerned if the ATOC database developed for the second phase of RJIS does not enable the effective updating of information within a reasonable period of time of being reported.

4.30 This section of the Guidance is seeking a commitment, where possible, that DPRS will be provided with the relevant information. This is in the interests of passengers and operators as it helps avoid potential problems with people waiting for journeys that can not be completed.

4.31 Therefore, we were extremely surprised by the threat of one operator to remove the entire fleet if a facility for disabled people was out of order for five days. This interpretation of the Guidance does nothing to inspire confidence in the operator in a reasonable approach.

Access to Station Facilities

7.12 A commitment to notify passengers when the level of accessibility is less than that normally provided at a particular station. For example, when a lift breaks down, access to one or more platforms may be affected. If it is, an operator must give a commitment to make reasonable endeavours to publicise this, for example, through its database (covered by paragraph 7.6), but also on its website, by notices at that station entrance and at other accessible stations along the route.

7.13 Operators must also commit to publicise in the same manner as stated in the previous paragraph (7.12) a timescale for when the facility will be functioning again.

4.32 DPTAC feel that the importance of good, accurate information, updated at regular intervals should be reflected within this section. Without this information many disabled people will not have the confidence to attempt to travel.

4.33 Despite being obliged under the terms of membership of DPRS to report facility breakdowns to the DPRS the overall response to this section was varied, although most operators covered this section in their policies, the degree of commitment was varied with operators utilising a number of different methods of publicity.

4.34 As with passenger assistance, some operators highlight Railtrack being responsible for some elements such as lifts, and not taking responsibility for those areas. We would have expected a common sense approach in this situation to include a statement with the effect that they will report any defects to the organisation responsible and work together on effective communication to passengers.

4.35 The drafts were poor at committing to providing information on the anticipated timescale for repair. Most operators overlooked this section or gave only qualified assurances. In some instances the only timescale given related to the period before the operator would notify the passenger the facility was not working with no comment on providing an anticipated date for rectifying the problem. We do not believe this approach benefits either operators or passengers.

4.36 Arriva Trains Northern make a commitment to give details where accessibility is disrupted and publicise how long it is expected to affect services, we would expect the same statement from other operators.

7.14 Operators must, without extra charge, commit to provide an alternative accessible service to take disabled passengers who are unable to use the affected station to the nearest accessible station.

4.37 An alternative accessible services enables disabled passengers to continue to use the affected service. We were pleased that most operators made a commitment to this effect but would question the lack of detail in some and qualifications, such as 'on core stations only', in others.

4.38 There was also concern that the commitment appeared to apply only to wheelchair users with little or no provision detailed for other disabled passengers.

4.39 If a station would otherwise be accessible but for the defective facility then the operator should make this commitment without qualification.

7.15 A commitment to ensure that where a station has automatic ticket gates or manual gates, where these are unstaffed, they must be locked open. The commitment must also apply whenever staff are not in attendance.

4.40 As this is a basic commitment, which should have been included in the station safety regulations at the time the gates were installed, there is no reason why all operators should not have addressed this section. Therefore, we were surprised at the number of operators who did not comment at all.

4.41 We would stress the importance of the gates being locked open rather than just left open, as stated in several of the drafts.

7.16 Operators must give a commitment that they will not close station entrances or gates if this will lead to a reduction in accessibility for disabled passengers to any platform or facility at that station, unless operators have first consulted with the Authority, the appropriate RPC/LTUC and local disability groups. Any changes to access will have to be approved by the Authority.

4.42 DPTAC were reassured that most operators gave a commitment to consult with relevant organisations before making any alterations to the station entrances.

4.43 However most drafts lacked the detail necessary ensure that the stated requirement was fully complied with. As a minimum we would expect the Guidance to be repeated in the Policy but we would also encourage operators to have identified local organisations to encourage dialogue and given sufficient notice to enable a response.

7.17 Operators must give a commitment that when procuring new automatic ticket machines they will require that these machines have the facility to issue tickets using the Disabled Persons Railcard (see also Section B4.3 Ticket machines of the code).

4.44 Whilst we welcome the commitment of those operators who gave this undertaking, we understand that some operators have done research into the availability of such a machine in order to conform to the Code and it currently does not exist.

4.45 We are concerned that the Guidance is not being used to stimulate the development of ticket machines as the requirement cannot currently be met.

4.46 We understand the SRA is considering commissioning work in this area to encourage the development of such products. We also understand that the Disability Rights Commission is interested in this area. We would urge co-operation on any development to bring forward the availability of such machines at the earliest possible opportunity.

Boarding the train

7.18 Train operators must list within the DPPP their rolling stock running in passenger service including: type; whether it is RVAR compliant or has exemptions (summarising them); how accessible in general terms the older rolling stock is, and; the routes on which the different types of rolling stock are normally scheduled to run.

4.47 The approach to this section varied widely with a few detailed descriptions of all stock and routes, such as Great North Eastern, but most drafts had only also vague descriptions or no information on rolling stock or schedules.

4.48 Some operators mistakenly included the information in the matrices rather than the text of the document.

4.49 As a bare minimum, we expected this section to detail any current exemptions applicable on regulated vehicles entering service since 1998. DPTAC would also expect the section to outline the general accessibility of older vehicles.

7.19 Where there is no step-free access, or a single step or kerb (greater than 15mm), to and from the station, then each train operator must give a commitment that ramps, fit for purpose, will be available at all staffed stations (these can be at the station or onboard the train) to facilitate the boarding or leaving of the train by wheelchair users, whether assistance has been booked in advance or not. When booking assistance (currently through the DPRS) it must be possible to arrange for ramps to be used at unstaffed station where there is step-free access, or a single step or kerb, to and from the station. Where assistance has been booked, operators must commit to a maximum of 10 minutes waiting time for people to be assisted off a train when the train reaches its final destination.

4.50 The majority of operators addressed the provision of ramps fit for purpose at staffed stations, however very few committed to arranging ramps on unstaffed stations when those with train staff and ramps could do so.

4.51 DPTAC are extremely concerned that some operators cite Health and Safety at Work Regulations in mitigation for not providing assistance. We would expect any operator who feels they have legitimate Health and Safety concerns to follow the normal procedure for seeking a dispensation only after alternative options have been considered and discounted by undertaking a risk assessment and proper consultation with all stakeholders.

4.52 Although recognising the problems of stepping distances work is on-going in this area and which should help address the concerns of operators.

4.53 In relation to the Guidance, the last sentence could imply that all journeys end at a terminus when obviously most do not. We also believe that 10 minutes is an unreasonable time to be left on a train when assistance has been booked.

7.20 Where trains are not reservable, the arrangements for providing assistance in obtaining a seat on the train must be detailed.

4.54 This is basic good customer care and we were most concerned about the lack of its inclusion. It implies a lack of assistance available, especially to those with less visible disabilities.

7.21 Details of the policy for carrying luggage for disabled passengers including whether there is a charge for doing so (see also 'reasonable adjustments' in Section A4.1 of the code).

4.55 This was well covered in most reports with provision of assistance to carry luggage where staff are available to do so. However some drafts lacked any clear policy, whilst others included unnecessary caveats such as health and safety restrictions.

7.22 Operators must also state their policy regarding the carriage of scooters for the mobility impaired on their trains.

4.56 This issue was well covered in many reports but not addressed in others.

4.57 The majority who expressed a policy did not take scooters. Some others also refused powered indoor wheelchairs and additional operators only accepted powered chairs that fitted within the reference wheelchair space envelope.

4.58 Although Chiltern would not accept scooters they are seeking to provide secure parking for powered scooters and develop a network of Shopmobility schemes along the route.

Service Disruption

7.23 Details of the operational arrangements for meeting the needs of disabled passengers when dealing with the breakdown of facilities and services that can affect access to passenger trains and stations must be detailed. These must include being able to rebook assistance through DPRS, where this is possible, when the original arrangements are no longer valid and the operator's arrangements for assisting disabled people when disruption occurs with no advance warning.

4.59 Whilst most Policies covered part of this requirement, a worryingly few policies included the ability to rebook assistance through DPRS. We have since been told that re-booking of assistance is not possible. Whilst we understand that station staff find it easier to deal directly with the station involved, this reduces the ability of the DPRS to record unmet journeys. We recommend that there should be a commitment to work together to develop a network wide policy for assisting disabled passengers during service disruption.

7.24 Description of the policy which applies in assisting disabled people in making connections including when trains are re-platformed at short notice; and where announcements and visual displays of departures and arrivals are made at short notice. For example: providing sighted guidance for visually impaired people; assisting with luggage etc.

4.60 It was difficult to identify a specific commitment where operators included it as part of a general customer care policy. However a few operators did committed to providing specific information to disabled passengers on arrangements during service disruption.

7.25 Where services or facilities for disabled passengers are altered or removed, a commitment to provide reasonable replacement facilities that are accessible.

4.61 Most drafts stated the operator would endeavor to provide reasonable replacement facilities that are accessible. See note under s7.32.

7.26 Details of the operators' emergency evacuation procedures for providing appropriate assistance to disabled passengers either at a station or on a train. These should include the methods and equipment used, and a summary of the appropriate fire regulations.

4.62 There was a worrying inconsistency present across the Policies. Many mentioned a safety policy, which was not expanded on or included in matrices. Some, however managed a very creditable statement which detailed staff involvement in evacuation procedures. This is a fundamental requirement of a Policy and we recommend that no DPPP should be approved without it. The emergency evacuation procedures for disabled passengers should be publicised in the same manner as escape routes for other passengers.

On-train

7.27 A commitment that on all trains, where the facility exists, audible and visual announcements of other than minor delays, 10 minutes or less, (including changes to stopping patterns, stopping short etc) must be given. Operators must consider that a visually impaired, or deaf, or hard of hearing person may be travelling and the consequences to that person of a station not being announced or a delay not being communicated. Operators must remind their drivers and train crew of the need to make clear consistent audible announcements, on approaches to stations, on all services. A commitment should also be given that when the name of the approaching station is announced consideration is given of the need to allow an adequate period of time for disabled passengers to prepare to leave the train. It is recognised that this may not always be possible where stations are at very short intervals i.e. 5 minutes or less travelling time.

7.28 A commitment that where passenger trains come under the scope of the Authority's code of practice 'Train and Station Services for Disabled Passengers', and a new audible and visual on-train public address system is planned, operators must ensure that the system complies with the standards in the code (Section A4.8 Passenger Trains) and has the facility to give announcements of each station stop and the destination of the train.

4.63 Overall the commitment to audible and visual announcements was poor. Most operators did not deal with the two separate commitments in sections 7.27 and 7.28. The first commitment is to use existing hardware to provide audible and visual information to the standard specified in the Guidance. The second commitment is to ensure staff make announcements effectively using existing facilities to the standard in the Guidance.

4.64 While new trains are bound by the RVAR regulations covering information, staff training about the importance of good information for disabled passengers should be embedded in the company to increase confidence of disabled people in train travel.

4.65 Information benefits all passengers. Research has shown time and time again that every passenger becomes frustrated not only by trains being late, but by lack of accurate information. Information is especially important for passengers travelling in the guard's van, who do not have a loudspeaker and cannot hear announcements.

4.66 Some operators highlighted the need for an industry wide solution that can be retro-fitted to existing vehicles. We would endorse that approach but do not see this as a replacement for using existing facilities effectively on all trains currently in service.

7.29 Where wheelchairs can only be conveyed in guards' vans, operators must give a commitment to ensure that the guards' vans are clean, properly lit, heated and ventilated.

4.67 This aspect should only affect a few operators for a limited period as such trains are required to be replaced by the end of 2004. Therefore it is disappointing that no such commitment has been made.

7.30 A commitment to detail the arrangements for assisting disabled passengers in making intermodal connections.

4.68 Response to this was patchy, which was disappointing as operating companies could have demonstrated their ability to co-operate with each other. Most operators limited their commitment to assisting disabled passengers to the perimeter of the station rather than thinking more broadly about connections with other modes of transport.

4.69 Integrated Travel solutions are also important for all passengers and funding is available from a variety of sources, e.g. Local Transport Plans and Rail Passenger Partnerships. It is also a politically sensitive subject and worth addressing.

Interchange with other modes

7.31 Where a licensed operator negotiates contracts with private hire car, minicab or licensed taxi operators for the use of taxi ranks at stations, operators must give details of how arrangements for the use of accessible taxis can be made. Operators must also give a commitment that accessible taxis will be able to ply for trade at stations where the contracted hire car operators do not have accessible vehicles. The contact numbers for these accessible taxis will be prominently displayed to the public. Contracts which do not allow these requirements to be met must be renegotiated at the first available instance.

4.70 The lack of awareness among operating companies about the taxi services offered at their stations was worrying. Few admitted to holding contracts and even fewer had audited whether there were any accessible taxis available in the locality.

4.71 DPTAC will be considering this issue further as part of its research into increasing the availability of private hire vehicles to disabled people.

7.32 Where, for whatever reason trains are replaced by buses, and disabled passengers are not able to use this substitute transport, operators must give a commitment to provide an alternative accessible service to the station they wish to reach e.g. an accessible taxi without additional charge. Operators must commit to giving audible and visual information to enable other disabled people to be able to find the substitute transport. Operators should note that section 248 of the Transport Act 2000 (currently not yet enacted) creates a legal requirement for substitute services to be suitable for disabled passengers as far as is reasonably practicable.

4.72 We are not convinced that sufficient consideration has been given to the availability of alternative accessible vehicles by many operators. More detail is needed on where from accessible buses, coaches and taxis would be sourced.

National Rail Standard

7.33 A commitment by franchised operators to adhere to the National Rail Standard 'Access and Travel Arrangements for Passengers with Disabilities' published by ATOC and for non-franchise licensed operators to use this Standard where relevant as a guide to best practice. Also stating that where there are differing standards in the Authority's code of practice, the Authority's code should always be followed.

4.73 This was covered reasonably well.

Consultation

7.34 A commitment to consult with the Authority in line with Section A4.8 of the code of practice (including where appropriate with the relevant RPC(s) and DPTAC), and when the operator believes they are not meeting any or all of the commitments within their DPPP.

4.74 Although generally covered in the drafts this many operators seemed to confuse this section with Section 7:16 which deals with consultation with the RPC when closing station entrances and gates.

4.75 We should encourage operators to develop positive, long-term relationships with local disabled people, which would be beneficial to both parties.

Published: 17 February 2003

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