Introduction
On the 18th January 2017, the Supreme Court of the United Kingdom delivered a landmark ruling concerning the case of First Group Plc v Paulley (FirstGroup Plc v Paulley, 2017). The case was to determine whether First Group Plc had discriminated against Mr Paulley, who is required to use a wheelchair, by not ensuring that the wheelchair space provided on their services could be vacated if occupied by a non-wheelchair user.
To date, there has been no appropriate explanation as to why the case succeeded in the County Court, failed in appeal at the High Court, but was ultimately successful in the Supreme Court. Examination of the relevant documentation available suggests that both legal teams for Mr Paulley and First Group Plc failed to account for, either in their submissions or court arguments, 4 pieces of information: a report by Stafford Pettersson Neath in 2006 for the Mobility Inclusion Unit of the Department for Transport; the minutes of a meeting of the Transport Committee of the London Assembly in 2005; and the Statutory Code of Practice and Guidance for Public Transport issued in 2006; and, Schedule 2 paragraph 3 of the Equality Act 2010. If they had, whilst the determination of the Supreme Court would have been the same, the case may not have needed to reach the Supreme Court.
The objective of this research blog is to provide a more detailed explanation of what bus operators should be doing to comply with the Equality Act 2010, taking into account the additional information.
The Original Incident
The incident in question occurred on Friday 24th February 2012. Mr Doug Paulley intended to board the 0940 service 99 bus to Leeds. There were 3 services operating between Wetherby and Leeds, First Bus Leeds X98 and X99 and Transdev Harrogate route 7. The reason why Mr Paulley chose the First Bus Leeds route was because it terminates close to the railway station at Leeds whereas the Transdev service terminates at the bus station three quarters of a mile from the railway station.
Whilst Mr Paulley had frequently used this service without any problem, on this day the wheelchair space was occupied by a buggy with a sleeping baby within it. The driver, in accordance with company policy, asked the mother if she could move the buggy from the wheelchair space, but she declined on the grounds that she would wake the baby. The driver, then informed Mr Paulley that he would have to catch the next service, which meant that he had to catch the direct train to Stalybridge, where he was meeting up with his parents, an hour later than intended.
The County Court case, and the subsequent High Court and Supreme Court cases, had to answer two key questions:
1. was Mr Paulley disadvantaged by the Provision, Criterion or Practice, and;
2. had First Group Plc taken reasonable steps to remove any possible disadvantage.
Were Reasonable Steps taken and was there Disadvantage?
To answer this question, it is important to understand who is responsible under the disability legislation to take reasonable steps. Doug Paulley brought his litigation case against First Group Plc because he was arguing that the policies of the company as a whole were responsible for him being unable to board the bus. This view was confirmed in the case brought before Middlesbrough County Court by Natalie Black and nine others against Arriva North East Ltd. The judge in this case, P H Bowers, made it clear that there was a clear separation of responsibility between the bus driver, who is governed by the amended ‘The Public Service Vehicles (Conduct of Drivers, Inspectors, Conductors and Passengers) Regulations 1990’ (Her Majesty's Stationery Office, 1990) and the company governed by the Equality Act 2010 (Her Majesty's Stationery Office, 2010). However, it should be stressed, as it was within Supreme Court case (FirstGroup Plc v Paulley, 2017) and the Statutory Code of Practice (The Disability Rights Commission, 2006) that whilst bus drivers may have a separate legal responsibility, the bus company that employs them is still legally responsible for their actions in a civil court.
It is therefore reasonable to conclude that the issues faced by all the claimants that responsibility lay with the bus companies concerned. However, it is important to note that the responsibility to make reasonable adjustments by bus operators did not take full effect until the 1st October 2010 (Her Majesty's Stationery Office, 2011). This is because of the original 1995 disability legislation exempting bus operators from the duty until such time as regulations were brought into force. The regulations requiring new vehicles to have a designated wheelchair space came into force in August 2000 (Her Majesty's Stationery Office, 2000). This was then followed by regulations governing the role of the driver in October 2002 (Department for Transport, 2002), and then the exemption from the duty placed on bus operators to make reasonable adjustments was removed through the Disability Discrimination Act of 2005 (Her Majesty's Stationery Office, 2005).
Within the 2005 Disability Discrimination Act and the subsequent Statutory Code of Practice (The Disability Rights Commission, 2006) and the guidance that supported the Code (The Disability Rights Commission, 2006 (a)), there was an anomaly, effectively an escape clause for bus operators to use to avoid their duty to make reasonable adjustments. Sections 19-21 of the 1995 Act detailed the duty being imposed on those organisations providing ‘goods, facilities and services.’ However, in section 21(6) an exemption to this duty was given to any organisation or individual if that change required a fundamental change to the nature of the service. This meant that in making the wheelchair space solely for the use of wheelchair users would change the principle of ‘first come, first served’ which had been the foundation of public bus services since their inception, and certainly since the Road Traffic Act 1930 (His Majesty's Stationery Office, 1930). This anomaly was removed by Schedule 2 (3) of the Equality Act 2010 (Her Majesty's Stationery Office, 2011) meaning that bus operators have to justify why they have not made reasonable adjustments and it is reasonable to conclude that both First Group Plc and Arriva North East may not have been aware of this requirement.
To determine whether First Group Plc or Arriva North East Ltd had taken reasonable steps it is necessary to establish when the conflict over the wheelchair space was known. The legislation governing the provision of a wheelchair space , the Public Service Vehicles Accessibility Regulations 2000, and the Public Service Vehicles (Conduct of Drivers, Inspectors, Conductors and Passengers) (Amendment) Regulations 2002 governing how drivers deal with the requirement to use the wheelchair space, came into force on 30 August 2000 and 1 October 2002 respectively. Therefore, the earliest anyone could have known about the issues surrounding the wheelchair space would have been then.
The earliest recorded evidence concerning the conflict over the wheelchair space was at a meeting of the London Assembly’s Transport Committee held on 9 June 2005. The debate between Angie Bray (Assembly Member) and John Cartledge from the London Transport Users Committee, was focusing on the lack of seats for elderly passengers and how buses could be redesigned, when John Cartledge made this comment.
‘John Cartledge: That is a very good point and I am sure Gordon will have some comments from the Age Concern perspective. However, it is certainly true that developments in bus design which have taken place with the very good intent of making buses more convenient and more accessible to some categories of users who probably were not able to use them at all in the past, may indirectly have had some of the side effects that you are hinting at. If you design a bus with a ramp to allow access to people in wheelchairs who previously could not travel by bus at all, that in itself is a good thing, but if the ramp is not always operative then that is a whole area of grievance that opens up that simply did not exist previously. Similarly, if you reserve an area within the bus for wheelchair or buggy parking, and wheelchair users or buggy users respond unexpectedly enthusiastically to this new travel opportunity that is presented to them so that you get more of them on the bus than there is room to accommodate at one time, you start to get conflicts between them which the driver is expected to arbitrate in as to who has priority in those circumstances, then again you are creating tensions that were not there before. It is a good that you do not have to remove the occupant of the buggy and fold the buggy before you can use every bus, but equally it is a bad thing if that buggy is then taking up space which somebody else in a wheelchair needs.
I am sure that these changes in bus design have contributed to the problem. We are involved with a Bus Design Forum which London Buses sponsors and a number of voluntary organisations are represented on, whose specific remit is to look at these kinds of conflicts and try to come to some shared view as to where the priorities lie and what the specification for the internal configuration of future designs of buses should be for very much that reason.’ (London Assembly, 2005)
It is clear from this statement that the consequences of providing a wheelchair space on public transport had not been foreseen at the time the legislation was introduced. The same meeting also provided an indication as to how bus operators and drivers were reacting to this increased demand for the space, from a comment made by Peter Hendy who was managing director of Transport for London’s Surface Transport.
Peter Hendy: I think I should probably start. This is a very difficult subject. I was corralled by two very vociferous women at the last GLA Women’s Conference who said that bus drivers should be responsible for asking the people with the second buggy to get the first buggy folded up. With the low-floor buses, whatever the other issues about their design, we have allowed a large space and for the first time we have allowed people with buggies and wheelchairs to travel on the bus without all the attendant fuss of folding them up and so forth. I think it is fairly unreasonable to expect drivers to intervene in circumstances where the goodwill of the passenger is concerned, but it must be obvious to people in many cases that if you get a second buggy on the bus one of them has to be folded up otherwise nobody can get down the corridor. The fact that nobody will do it suggests to me that the driver’s intervention in many cases would not be worthwhile. They are not advised to get out of the cab because most of the serious assaults that occur on bus staff are because they leave the cab, and I do not think that is unreasonable in these circumstances.' (London Assembly, 2005)
So, bus operators were clearly aware of the problem in 2005 and were relying on the goodwill of passengers to resolve the problem and advising drivers not to get involved in the dispute. But, as has been mentioned in an earlier paragraph, there was no legal requirement to change their practices because it would have meant having to change the principle of ‘first come, first served’ which underpins the public transport service. However, that is probably not the real reason why bus operators did not deal with the developing conflict over the wheelchair space.
The court case brought by Doug Paulley against First Group Plc identified the belief by bus operators that all they had to do was just comply with the minimum standards set by the legislation. Tyler (2002) raised this belief when discussing the problems facing planners and society as a whole in developing an accessible infrastructure to the bus network. He was suggesting that there needed to be a contract, or an understanding, between those developing and providing the services with those using it. He argued that whilst in any such contract a minimum standard had to be established, there was an inherent risk.
‘Of course, the minimum standards have to be defined. The temptation is to define standards in terms of inputs (e.g. measurements of size or distances). However, these become very inflexible and can become outdated very quickly. Also, it is very easy for a standard which has been set as a minimum to become the norm in practice, thus tending to reduce the possibility for improvements over time. This also tends to reduce the basic standard in the short term to that of the worst acceptable level.’ (Tyler, 2002, p. 10)
Whilst Tyler was specifically talking about infrastructure, it did include the provision of a wheelchair space on the bus itself, and from the County Court case at Leeds, it becomes evident that bus operators were taking this view, as can be seen from the company policies adopted at the time.
‘Because the low floor area is available on a first come, first served basis, there may be times when it is already occupied by other passengers. If there is room elsewhere on the bus, the driver will request the occupants to move and/or to fold a buggy. Should they refuse or be unable to move, we regret that a wheelchair or scooter user will not be allowed to board as they cannot be safely carried anywhere else on the bus’. (Arriva, 2011)
‘Wheelchair users have priority use of the wheelchair space. If this is occupied with a buggy, standing passengers or otherwise full, and there is space elsewhere on the vehicle, the driver will ask that it is made free for a wheelchair user. Please note that the driver has no power to compel passengers to move in this way and is reliant upon the goodwill of the passengers concerned. Unfortunately, if a fellow passenger refuses to move you will need to wait for the next bus.’ (First Bus PLC, 2014 (a))
Transport for London took a slightly different approach but ultimately the effect was the same.
‘What if people don’t make room?
You must ask passengers to move, using the iBus pre-recorded message. Remember, the dedicated wheelchair space is the only place wheelchair users can travel safely. If other passengers seem unwilling to make space for a wheelchair user:
Use the PA system to explain that the wheelchair bay is the only safe place for wheelchair users to travel.
It can be stressful travelling with children in buggies, so be polite as this is more likely to get passengers to cooperate. Explain you’ll give them the time they need to move or fold down their buggy and do not move off until they are safely re-positioned.
Sometimes it is possible for a wheelchair and an unfolded buggy to share the space. You should allow this provided the wheelchair user is in the correct position and the buggy is not blocking the gangway.
If passengers are unwilling to move, despite your request, do not ask them to leave the bus:
Do not close the doors and move off until you have explained to the wheelchair user they will need to catch the next bus and the reason why.
If the wheelchair user has to wait, contact your garage so the driver of the next bus can be made aware’ (Transport for London, 2012, p. 59)
To identify what reasonable steps should have been taken or can be taken, it is necessary to first establish why the problem is occurring. A detailed explanation was given in a report for the Department of Transport by Stafford, Pettersson & Neath (2006). They identified that whilst the wheelchair space had been designed for one objective, two groups within society, mothers and wheelchair users, who were both using the space to enable them to overcome the social isolation they were encountering. As a result, there was an unanticipated demand for the space. This should therefore lead to the question, how large was that demand?
It was a question that only one authority, Transport for London, and one bus operator, Lothian Buses, can be identified as attempting to answer. In London, through the travel demand surveys conducted by the Mayor of London’s Office, it was estimated that between 4 and 5 times more buggies and pushchairs use the wheelchair space than wheelchairs (Transport for London, 2013 (p)). In Edinburgh, rather than conducting a random questionnaire survey,
Lothian buses conducted a physical count on two of their frequently used services. They found that over a two-week period there were 10 times more buggies using the buses in Edinburgh than wheelchairs (Lothian Buses, 2012).
It is therefore reasonable to conclude that throughout the whole of the country, more parents with buggies use buses than wheelchair users and means that maintaining the policy of ‘first come first served’ with only the wheelchair space available, the probability of the wheelchair space being occupied by a buggy when a wheelchair user wishes to board would be high.
With such a large problem facing bus operators and ultimately the bus driver, what could have or can be done to mitigate the increased demand for space.
To answer this question, it would be useful to examine a decision made by Lothian Buses in 2019 to purchase over 42 Enviro 400XLB vehicles from Alexander Dennis. At the time criticism was made to Edinburgh City Council, the ultimate owners of Lothian Buses, that the company was making a backward step by purchasing vehicles that had only one space for buggies and wheelchairs (Edinburgh Evening News, 2019). From the information available the question that needs to be posed is whether the company’s decision was flawed.
The starting point in this discussion must be with the guidance given in 2006 by the Disability Rights Commission (The Disability Rights Commission, 2006 (a)), which accompanied the Statutory Code of Practice issued for transport vehicles (The Disability Rights Commission, 2006). The guidance stated:
‘The DRC recommends that the ultimate aim for all transport providers should be to integrate provision for disabled customers to the point where it is automatically planned into the provision of any service, vehicle or building and, ideally, mainstreamed within that provision. This is in order to prevent, wherever possible, a situation in which disabled people are separated out from other passengers as ‘special cases’.’ (The Disability Rights Commission, 2006 (a), p. 9)
The Mayor of London calls this process mainstreaming and describes it as:
‘where the principle of equality is integrated into everything the organisation does and the work that everyone does on behalf of the organisation’ (Greater London Authority, 2016 (a), p. 36)
The company claimed in a press release that the new buses were being used on two of the company’s busiest routes, which conveyed over 10 million passengers, and that they would bring additional comfort to the passengers who use them (Lothian Buses Ltd, 2019). With only the wheelchair space available to both parents and wheelchair users, to maximise seating capacity, did the company mainstream equality into its decision-making process. The reality is that it is difficult, even though the company is covered by the Freedom of Information regulations, to determine the decision-making process. However, it is possible to piece what information is available with reasoned judgement to determine what the decision-making process was and evaluate if the mainstream had integrated equality into their decision making.
The routes selected were route11 (Figure 1) and route16 (Figure 2).
Figure 1. Route 11 (Lothian Buses) Ocean Terminal – Hyvots Bank[1]
Figure 2. Route 16 (Lothian Buses) Silverknowes - Colinton[2]
At the time the decision was made, 2018, all of Lothian’s city routes operated on the principle of cross-city routes, where the service starts on one side of Edinburgh, is routed through the centre of Edinburgh, and then out to another part of the city. The objective of this principle is to reduce the number of routes being operated, as using the spoke and hub plan requires double the number of routes being operated and possible resources.
The level of service on both routes 11 and 16 during the day (Monday to Fridays) was approximately every 10 minutes, with additional services operating in peak hours. It is therefore reasonable to assume that the level of demand being placed on these services throughout the day was reaching a point where overcrowding was a regular occurrence. Therefore, it would be reasonable for Lothian Buses to believe that passengers may be put off using overcrowded bus services, resulting in passengers turning to their cars or opening up the route to competition (Brassington & Pettitt, 2003, pp. 977-978), from either First or Borders Buses. In such situations it is reasonable for bus companies such as Lothian Buses to either consider altering the level of service provided, which in this instance would mean increasing the service which might not be possible due to the physical constraints of available drivers and vehicles, or by providing a higher quality of service through the provision of larger buses with more seats and comfort (Kotler & Armstrong, 1991).
From an FOI request made by Doug Paulley in 2018, the company admitted that even though it did not have evidence detailing the decision making process, they were aware that the dimensions of the wheelchair space were larger than the minimum standard and therefore it was possible to convey both a wheelchair and a buggy (Lothian Buses Ltd, 2018). Whilst the company could argue that they had not made a backward step, they had failed to show that they had mainstreamed equality into their decision-making process fully because they had not considered adequately the possibility of a challenge which would require documentary proof.
In addition, providing adequate space for both a wheelchair and buggy is not sufficient, especially when Lothian Buses, through their accessibility report, they established that there was a high possibility of the wheelchair space being occupied by two buggies when it was required by a wheelchair user. This meant that they required adequate policies to deal with that eventuality. Their policy of accepting buggies was detailed on the company’s website (Figure 3)
Figure 3. Lothian Buses guidance on allowing buggies onto services[3]
The first observation about the policy is that it does not operate under the assumption that the goodwill and citizenship of the passengers would prevail in resolving any conflict over the space. Whilst this may happen in most cases it cannot be relied upon, as seen in the court cases. It is also important to remember that the controlling factor in any dispute over the wheelchair space is the driver. At the beginning of any trip, the driver will expect, as seen from the usage figures produced by Transport for London and Lothian Buses, at least one if not two buggies at any one time to be on part or all of that journey. Unless the wheelchair user is a regular passenger, travelling on the same service, drivers will not know until they reach the bus stop, a wheelchair user wants to board, meaning that if the wheelchair space is occupied a problem is likely to occur.
However, there are problems with the guidance given. Firstly, the question that must be asked with this question is how many buggies can be folded up? This was a question posed by the accessibility review conducted by Lothian Buses in 2012 (Lothian Buses, 2012). The researchers examined web sites where buggies were sold and evaluated how many could be folded (Table 1).
Table 1. Analysis of Buggies on the Market[4]
Whilst a significant number of buggies can be folded in some form or another, it would be difficult if not impossible for the driver to actually know if the buggy being brought onto the bus is collapsible, and even if the driver asks the parent, they may not know. It should noted though, that the company has not performed a further review of the number of buggies and wheelchairs using their services, and as a result the information given may not be accurate and therefore cannot be used as a defence against any claim for discrimination.
The second problem with the guidance is the ability of the driver to control the flow of passengers onto the bus. On London’s buses, and probably most of the UK buses in the current Coronavirus epidemic, there is a physical barrier between the driver and the passenger which creates problems with both the driver and the passenger hearing each other. If the passenger has a prepaid ticket or card, then they will just swipe the card and proceed onto the bus.
These problems can be overcome, but it requires the driver to have the confidence to control entry to the bus, which he or she is legally required to carry out. This can only happen if the driver has confidence in the supervisors and management of the bus operator, which based upon a report produced for Transport for London on driver fatigue, is not always present (Filtness, et al., 2019).
A Further Problem
In the course of examining the published policies of First Group Plc, a further issue of non-compliance with the Equality Act 2010 was identified, relating to the process of indicating that a passenger wishes to board the bus. The Conditions of Travel produced by First Hampshire and Dorset Ltd (2020), which is a template produced by the parent company, state in paragraph 3.2 (figure 4) what a passenger must do to stop the bus.
Figure 4. Stopping the Bus – Conditions of Travel (First Hampshire and Dorset Ltd)
The passenger must clearly indicate their intention to board the bus. This is in line with the ‘Passenger Code’ issued by Bus Users UK (Bus Users UK, 2019), a charitable organisation aimed at making buses inclusive and accessible. The conditions of travel and the guidance assume, in general, that the passenger can signal or more importantly is able to clearly see the bus approaching. In London, Transport for London instruct drivers to pull in at any stop where there is a potential passenger, on the assumption they are unaware or unable to signal. Therefore, requiring someone to clearly signal in order to stop the bus could be in breach of the Equality Act 2010.
Conclusion
The case brought by Doug Paulley against First Group Plc clearly showed that at least one bus operator had failed to do enough to comply with the equality legislation. In examining the decision making process of another bus operator it becomes apparent, using the methodology prescribed by the Disability Rights Commission (now the Equality Commission), that bus operators may not be examining the bus journey as a whole, and therefore discriminating against various groups covered by the Equality Act 2010.
Therefore, in addition to what has already been done, to comply with the Equality Act 2010, bus operators should:
1. Ensure that they periodically evaluate the demand for the wheelchair space.
2. Ensure that bus drivers can adequately control the flow of passengers onto their vehicles and ensuring they can limit the number of buggies being allowed onto the bus, thus ensuring that in the eventuality of a passenger in a wheelchair needing to board, they can do so.
3. Ensure that the bus operator’s policies are not only available online and clearly marked on the buses themselves, but also regular publicity of the operator’s policies are provided on all social media platforms.
4. Ensure that all drivers are aware that they must stop at all stops where a passenger is located unless that passenger clearly indicates that they do not wish to board. Bus operators must ensure that their policies reflect this.
5. Bus operator’s must remember that their decision making processes can be challenged in court and therefore they need to ensure that every decision made is recorded and the reasons why the decision has been made.
[1] (Lothian Buses Ltd, 2020 (a)) [2] (Lothian Buses Ltd, 2020 (a)) [3] (Lothian Buses, 2020) [4] (Lothian Buses, 2012, p. 24)
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