Doug Paulley's blog

disability, data protection, activism and other such

Station Accessibility Info

Posted on by Doug Paulley

Pie chart. Title All Comparable Attributes. Agree 396 15% Differ 2190 85%.

I have been researching the accuracy of rail station disability accessibility information for several years. The difficulty with inaccuracy of such has been recognised by the Office of Rail and Road: (PDF)

Inaccurate, incomplete or unclear information may result in assistance being booked for a journey that involves a station which proves to be inaccessible to the passenger.

… Bookings are ‘designed to fail’ from the outset due to inaccurate station information.

There are long-standing issues with the station information held on the National Rail Enquiries website that affect prospective passengers and booking agents. The working group estimated that a significant number of the station pages on NRE display some form of inaccurate information.

My research compares data in Knowledgebase / National Rail Enquiries against that published in Train Operating Companies’ accessible travel policies.

Research results

Pie chart. Title All Comparable Attributes. Agree 396 15% Differ 2190 85%.Pie chart. Title Accessible Loo. 1,001 87% Agree 154 13% Differ.

So for Britain’s 2,500+ stations, 2,190 (85%) have some item of accessibility data differ between the ATP / DPPP and National Rail Enquiries. For example, of those stations that have information on the provision or otherwise of accessible toilets, 154 (13%) differ between the two information sources – either National Rail Enquiries says there is an accessible toilet and the ATP says there isn’t, or vice versa.

Lobbying Rail Delivery Group

I’ve been emailing the Office of Rail and Road, Train Operating Companies and Rail Delivery Group about this. Here’s an extract from my most recent email to Rail Delivery Group.

DPPP/ATP vs Knowledgebase comparison

I have many thoughts and experiences with Knowledgebase, predominantly through my research into consistency of accuracy in station accessibility feature information between different sources – e.g. DPPPs/ATPs, Knowledgebase and TOC accessibility maps. Like the ORR, I have significant concerns about its accuracy.

Such isn’t an academic exercise: I have had multiple experiences with such information being inaccurate causing me difficulties on the ground.

I attach a spreadsheet showing a comparison of station information from Knowledgebase against that in their DPPPs / ATPs. There are significant differences. Whilst some of these differences may be due to the comparative ages of information – e.g. station features for stations in DPPPs written up to 4 years ago may well have changed – the number of discrepancies is too substantial for this to account for it.

Examples include the 296 stations where the ATP says there’s a disabled toilet but Knowledgebase says there isn’t (have they all been closed since the DPPP / ATP were published?!) and the 42 where Knowledgebase says there is an accessible toilet but the ATP / DPPP says there isn’t.

And many, many, many more. The spreadsheet shows inconsistencies in 2194 of the 2586 stations’ accessibility data. For those 2194 stations at least one element of accessibility data differs between Knowledgebase and the station information in the relevant ATP / DPPP. Many stations have more than one such discrepancy – across those 2,194 stations, there are 6,145 instances where an element of a station’s accessibility information differs between that stated in the DPPP/ATP and that in Knowledgebase. (That’s excluding instances of such information being missing from Knowledgebase.)

Structural errors

More concerning to me is that the structure of Knowledgebase simply makes it impossible for station operators to input accurate information.

Take “Step Free Access Coverage”.

The current Knowledgebase Data Feeds Specification and the Developers Guide for the Stations V4 XML Feed say:

<StepFreeAccess><Coverage>
Coverage of step free access. Contains 1 of the following values: wholeStation / partialStation / allPlatforms / noPartOfStation / unknown.

The RDG Knowledgebase Stations Data Feeds Specification has been updated and re-signed off on a regular basis, and was signed off in 2019.

The Knowledgebase Stations XML schema confirms:

<xsd:simpleType name=”StepFreeAccessCoverageEnumeration”> <xsd:restriction base=”xsd:NMTOKEN”>

<xsd:enumeration value=”wholeStation”>
<xsd:annotation><xsd:documentation> The whole station is accessible, including all platforms and ticket office. </xsd:documentation></xsd:annotation></xsd:enumeration>

<xsd:enumeration value=”partialStation”>
<xsd:annotation><xsd:documentation> Parts of the station are accessible. Used when neither allPlatforms nor wholeStation are applicable. </xsd:documentation></xsd:annotation></xsd:enumeration>

<xsd:enumeration value=”allPlatforms”>
<xsd:annotation><xsd:documentation> All platforms are accessible, but not the ticket office. </xsd:documentation></xsd:annotation></xsd:enumeration>

<xsd:enumeration value=”noPartOfStation”>
<xsd:annotation><xsd:documentation> Neither the platforms nor the ticket office are accessible. </xsd:documentation></xsd:annotation></xsd:enumeration>

<xsd:enumeration value=”unknown”>
<xsd:annotation><xsd:documentation> Accessibility details are unknown. </xsd:documentation></xsd:annotation></xsd:enumeration> </xsd:restriction> </xsd:simpleType>

I therefore don’t understand why it is not currently possible for station operators to select “partialStation” or “allPlatforms” – and why all stations are thus arbitrarily classified as having full or no step-free access. The XML data feed specification is signed off year after year, going through a formal review process, and remains with these options in, yet they aren’t actually possible to select; in actual fact only “wholeStation” or “noPartOfStation” can be selected.

One wonders: what is the point in having a formal specification and schema approval process, if the resulting document isn’t accurate nor followed? But more importantly: what is the point of having this crucial information in Knowledgebase, given that its implementation means the information it holds simply can’t be trusted?

Micky Ball and Michael Adlington recognised in 2017 that this needed to be changed. So did Scotrail, who emailed me in 2017 to say:

“ScotRail is experiencing difficulties with updating the ‘Step-free access coverage’ section due to a technical issue with the NRE website, which is only allowing for ScotRail to tick ‘Yes/No’ for this field without the option to edit text. This is an issue that can only be addressed by Rail Delivery Group, which ScotRail has requested be addressed as quickly as possible.”

Other anomalies include: there’s a field for “Station Categorisation”, presumably Step-Free Access Categorisation using the ORR’s definitions – but it’s only filled in for 235 stations (GTR’s), and in any case it only allows a single-character entry, so not “B1, B2 or B3” as described by the ORR.

Every station (all 2,500+) is down as having an “induction loop” – even those that have no ticket offices, audio announcements, or help points, so I question what audio information can be being provided over induction loops at these stations!

“Last Changed” doesn’t update for some stations – e.g. Knowledgebase claims Maybole’s data was last updated in November 2016 yet the Step Free Access Note states “This is a Category A Station” – a categorisation invented by the ORR in 2019.

TOC accessibility managers tell me that they spend considerable time and money surveying access features at all their stations, provide this information to NRE, mass-upload it – then find that the database has been reverted to an earlier version, undoing all the updates, without the TOC even having been informed.

This simply doesn’t work.

Knowledgebase replacement deadline, and interim issues

The Knowledgebase replacement has been promised for many years. I was promised it by the end of 2016. Micky Ball and Michael Adlington promised it by the end of 2017. There have been any number of slipped deadlines and so on.

I now understand that the replacement is not likely to be implemented until the end of 2022? I’d be grateful for any information on this process and deadlines.

I guess the above issues, and many more, show why such a replacement is needed. The problem is: the existing system isn’t viable in the meantime. It has been creaking on for far too long, unloved, unmanaged and left to rot (to say nothing of Stations Made Easy); with work-around after work-around.

The result is that disabled people suffer. I suffer; the frustration of attempting to find accurate information for planning and booking journeys, finding “on the ground” that journeys I wish to complete aren’t actually possible; that I can’t hear announcements or that I can’t go to the toilet and so on. And so do others.

I would argue that the existing system must not be expected to last until it is replaced; especially as the replacement timescale may well slip, given the RDG’s planned Knowledgebase replacement has suffered so many slipped deadlines already (and similarly the Passenger Assist app etc.) It would seem that the ORR are of a similar mind: I have been collaborating with them for their current audit of the accuracy of station accessibility information, and I’m aware of what emphasis they (rightly) place on such.

What can be done about it?

Can I help?

As you have probably gathered, I care about this a great deal. Accurate information about accessibility is every bit as necessary and important as accessibility itself: neither is of any use without the other; and this seemingly dry subject has a real, human, cost on disabled people’s ability to access public transport.

The spreadsheet shows potential inaccuracies in 2,194 of 2,586 stations’ data.

So: what would be practicable? How can I help to ensure the accuracy of information in Knowledgebase until the new version is released? How can I contribute to ensuring the new version is more fit for purpose than the current mess? And how can RDG, as owners of this data, improve this?

Hopefully Rail Delivery Group will respond positively to the email above and actually do something about this egregious and potentially harmful access information provision failure.

Settle and Carlisle charter accessibility

Posted on by Doug Paulley

I went on the new charter service yesterday. I had an excellent time.

A fast bald bloke is sitting, grinning, on a train, next to a window. He's a wheelchair user
Me, sitting in the wheelchair space, holding some gin

Finding out whether I would be able to travel was very difficult because information on its accessibility (to wheelchair users or other disabled people) wasn’t published anywhere (at the time). It’s still far from complete now.

The service is actually run by Locomotive Services TOC Ltd. Their Accessible Travel Policy isn’t entirely accurate about this train either. So I thought I’d help out.

We can accept foldable wheelchairs and have a ramp so that passengers can board. We also have one dedicated wheelchair space aboard per train which is availble for both standard and electric wheelchairs. However as the stations we serve are run by Northern Railway we can’t accept mobility scooters aboard the train or at stations. For disabled access please email in advance before booking your ticket.

The current website accessibility text

That’s not the full story.

Carriage D, with the wheelchair space (at the south end of the train yesterday) was once a standard first class coach without a wheelchair space. They made a wheelchair space in the cartage by removing a chair and table.

That means the carriage doorway has a very narrow opening. My wheelchair is about 68cm wide. I had to remove one rear wheel and handrim to fit through the doorway. I reckon the doorway is less than 60cm wide. Given that the UK standard for railway carriage wheelchair access is to accept a 70cm width wheelchair, this is a significant restriction – most wheelchairs won’t fit through.

There’s no disabled toilet on board. The toilet is very inaccessible and impossible to even attempt to enter in a wheelchair. Whilst the journey is supposed to last 1hr 10mins ish, the train can be delayed, as it was yesterday, thus taking 1hr 30mins with no access to the loo. Skipton and Appleby stations have good disabled toilets available and open – I don’t know about Appleby.

There’s no table available in the wheelchair space. So I had to juggle the gin!

The coaches were recently retired from standard usage on the mainline, on Anglian railways, and had been recently refitted. So the lighting is very good, the announcements were loud and clear (RASTI levels good), the upkeep is excellent, the suspension butter smooth, and in general the whole thing is in good nick.

The stations are managed by Northern, so the charter company told me to book assistance with Northern passenger assistance. But the trains, as charter trains, aren’t in the national rail timetable, and Northern’s assisted travel people were utterly flummoxed by this. They couldn’t get their head round it, their systems didn’t allow them to book assistance on a train that didn’t appear to exist, and in the end they gave up.

Happily, the charter staff e.g. the guard were excellent, very friendly, efficient and knowledgeable. The Northern staff at Skipton and Appleby were very helpful and competent (they always are, in my experience.) So there’s no problem. I would recommend turning up a little early to arrange assistance if you don’t book in advance.

So this service clearly isn’t fully accessible to wheelchair users; many will find it impossible to enter. And the “official” access information about it is limited and inaccurate. But if you can access it, it’s an excellent trip.

(A steam train I saw whilst at Appleby)

Disabled People Deserve Equal Access to Critical Care – Judicial Review

Posted on by Doug Paulley

Many disabled people may be left to die so that others can be saved. That’s the impact of likely coming increased demand for hospital treatment, intensive care beds and ventilators, according to multiple reports in the Press.

Cartoon: Wheelchair user next to a hospital bed, pointing to a notice saying "Do Not Resuscitate". He is asking a nurse,, Who is responsible for that? The Grim Reaper, with a white coat and stethoscope, is stalking away.
With thanks to Dave Lupton / Crippen Cartoons for the excellent cartoon.

Guidance by the National Institute for Clinical Excellence, from the British Medical Association, letters from Clinical Commissioning Groups to care homes, letters to individual disabled people from GPs, the NHS’ “Decision Support Tool” and others, all suggest that disabled people will be left out in competition for treatment with able-bodied people. Whilst there has been some correction, I still have no confidence that disabled people will have anything like equal access to critical care services.

The BMA advice is stark:

Doctors would be obliged to implement decision-making policies which mean some patients may be denied intensive forms of treatment that they would have received outside a pandemic. Health professionals may be obliged to withdraw treatment from some patients to enable treatment of other patients with a higher survival probability. This may involve withdrawing treatment from an individual who is stable or even improving but whose objective assessment indicates a worse prognosis than another patient who requires the same resource.

The nature of many disabled people’s impairments is that compared to non-disabled people, recovery may be less likely, take longer or be “incomplete”. Under this guidance, it would appear that disabled people would not be offered intensive treatment they may receive outside a pandemic. I don’t think that disabled people’s right to life should be written off in such a manner.

The Government could and should have published guidance on how doctors will decide which people will receive life-saving treatment during the pandemic. They haven’t done so. This must be challenged.

So we’re threatening the Government with judicial review. I’m one of four claimants working with Rook Irwin Sweeney Solicitors and barristers Steve Broach and Ruth Keating of 39 Essex Chambers (all acting pro bono i.e. working for free – I’m incredibly grateful to them!)

We have written to the NHS, the Government and the British Medical Association threatening judicial review for failing to respect disabled people’s right to life. We have requested they respond on or before Thursday 16th April, or we will be forced to challenge their failures through judicial review in the High Court.

I very much hope that the Government, NHS and BMA see sense, and produce guidance on life-saving treatment prioritisation. Such guidance should safeguard disabled people’s right to life.

Read the Press Release on the Judicial Review (PDF format)

Jon Hastie, who made this video, isn’t part of this legal action, but I think he makes very clear why the action is necessary.