As the UK Government is currently undergoing a consultation to review the Public Service Vehicles Accessibility Regulations 2000, to which the deadline for submissions is 11:45pm on 4 September 2023, I have decided to write a response, not just to the consultation but also to inspire transport authorities, bus manufacturers, bus operators, etc. to improve accessibility for new buses in London, the UK and elsewhere. Bear in mind though, I’m not an expert at vehicle design.
So here are my suggestions to create the most accessible zero-emission bus for London and elsewhere.
The new zero-emission bus should contain:
• The latest bus safety standards (developed by TfL to improve bus safety),
• High-specification interior design (a first class experience for bus users with WiFi, USB ports, sunroof at top deck, etc.),
• High-backed seats (with headrests to reduce whiplash injury),
• Priority seat moquette design (to make priority seats more identifiable for the disabled, older people, etc.),
• Fully low flat floor on the lower deck (to provide ease of approaching the seat),
• Larger wheelchair space (of 2 metres),
• Two wheelchair areas (without sacrificing priority seats by the front),
• Stylish exterior design (to provide street presence).
• Ultra-thin solar panels to generate renewable energy that supplies all electronic devices on board and recharges the bus.
• Interior and exterior display screens (to provide route information, service branding, advertising, etc.)
• Eink to rapidly change external livery without repainting the bus.
• Two-doors and one-staircase (for local transport authorities with enhanced partnership and franchising, in line with London’s buses).
• Alternatively, a variant with three-doors and two-staircases (ideal for busy routes to improve boarding and exit flows at bus stops, and bus rapid transit services).
Below is my explanation and research on how buses in the UK (and elsewhere) should be improved.
Interior design
The interiors of the newly accessible zero-emission bus should be high specification to enhance the bus user’s experience as recommended by the UK Government’s Bus Service Improvement Plan and the National Bus Strategy.
National Bus Strategy: Bus Service Improvement Plans
95. Disabled people and those with protected characteristics must be able to use bus services as easily as other passengers. Making buses more accessible (not just the vehicles themselves, but also bus stops, bus stations, and by providing excellent customer service) also benefits other passengers.
98. Buses should offer end to end accessibility and provide ample areas for pushchairs and luggage in addition to the wheelchair space, so that everybody can travel with confidence. They should also offer audible and visible information, in addition to WIFI and charging as standard - allowing people to work and interact online whilst they travel and make better use of their time. More buses, particularly in rural areas, should also carry cycles.
High specification interiors are now specified by TfL as part of their new zero-emission bus procurement by bus operators for their route contracts as part of their Bus Action Plan.
Transport for London’s Bus Action Plan
Action 2
Improve the experience for customers in vehicles and at bus stops, shelters and stations by:
• Identifying and trialling new layout and design features that can improve the customer experience and accessibility inside the bus, including better lighting and seating, and measures to improve thermal comfort, beginning with 29 vehicles on route 63 in 2022.
• Looking to develop innovative new technology and services to provide improvements for bus customers, working through our Innovation Hub to engage with new suppliers and partners
Action 3
Protect and enhance the accessibility and inclusivity of our network by:
• Working with diverse communities at a pan-London and local level to explore opportunities to enhance the inclusivity of bus stops and vehicles, seating, layouts, customer information and the broader experience of travelling by bus
• Introducing new priority seat moquettes (starting with 1,000 Routemaster buses by the end of 2025), and inclusive signage onto the bus fleet
The colour scheme for the interiors should remain different for each bus operator. Also service branding (i.e. Bristol’s Metrobus, East London Transit before New Routemasters) which helps visually impaired and other people to know which service they are on by looking at the branding of the interior and the moquette on seats. I welcome the use of colour schemes and seat moquettes from various vintage buses such as the MCW Metrobus/Leyland Titan and the AEC Routemaster being used for the new zero-emission bus to provide a nostalgic experience for bus users.
The new bus should have two spaces dedicated to wheelchair users (or for one buggy and one wheelchair.) Here's an example seen in Singapore and there are more examples mentioned below in the article.
In Hong Kong and Singapore, some of their buses have two wheelchair areas.
— CLondoner92 (@CLondoner92) March 24, 2023
Still image taken from YouTube video:https://t.co/dfoyDcdZ5Ehttps://t.co/XECZl8AaWY pic.twitter.com/n2grtEYwn8
The adoption of two wheelchair spaces for the zero-emission bus may require a longer length to sustain the number of seats on the lower deck.
According to TfL’s New Bus Specification Version 2.4, the size of the wheelchair space for new zero-emission buses is 2 metres.
Here’s a brief extract from the New Bus Specification document on accessibility:
7 Accessibility
The completed bus must be designed as a low floor.
A minimum of 4 priority seats shall be provided and must be clearly identified by the standard (LBSL Issue) notice.
A minimum of a further 2 additonal “preferential” passenger seats shall be provided in the low floor area (see table 6-1), for passengers who are less able to stand or who are travelling with small children. These will be of similar space requirement to the priority seats. Preferential seats must be clearly identified by the standard (LBSL Issue) notice.
Priority or preferential seating on the low floor area shall maximise under-seat space as much as possible, for use by guide or assistance dogs. The height from the floor to the top of the seat cushion should be approximately 490 mm to achieve this All of these seats will be fully defined on the approved seating layout as approved by TfL and uploaded to the TfL BVS Database.
All buses must make provision to carry a wheelchair and its occupant. Buses shall be designed such that wheelchair access is via the door positioned mid wheelbase on two or more door buses or via the front door on single door buses.
Objective wheelchair area length shall be ≥2000 mm unless agreed otherwise by the Nominated Officer.
The lower deck should have a fully low flat floor as designed by bus manufacturers Arrival (link to second video) and Foton Motor for their zero-emission single-deck products.
Seat design
As Transport for London is undergoing the refurbishment of New Routemaster buses, they have specified priority seating designs by featuring a different type of moquette with the words “this is a priority seat” to make it easy for passengers that the seats are meant for.
The high-backed seats are now widely chosen for new buses in the UK as part of the high-specification interiors; it is also a requirement as part of TfL’s bus safety standards to reduce whiplash injury.
High-backed seats are now the norm in London and various parts of the UK.https://t.co/zvo1Uzx1OM
— CLondoner92 (@CLondoner92) August 7, 2023
Which is now a requirement for London's Buses as part of TfL's Bus Safety Standards.https://t.co/QgXWWSOqp3https://t.co/hey6gFTWrb pic.twitter.com/93B4xhiAQ8
Vehicle styling
I'm not advocating for TfL to re-launch the New Routemaster project as the concept is obsolete now, as I stated in my previous article from 2020, bus manufacturers have adopted design cues of the NRM for their double-deck products. You may also be interested to read my detailed article about the New Routemaster from late February 2022, marking the 10 years of passenger service.
The styling of the zero-emission bus should have an iconic stylish design helping to attract people to travel by bus.
In a previous article reviewing Alexander Dennis’ new Enviro400EV, earlier this year (2023), I stated:
“My idea extends to the bodywork of the bus, as they should be creative on having various range of shapes and styles to enable bus operators and transport authorities to make their bus services attractive and to deliver street presence. It’s time for bus manufacturing to progress from conventional and make their products more modular to enable tailor-made designs of zero-emission buses. And yes, the term modular is used by electric vehicle manufacturer named Arrival as they have their own single-deck electric bus.”
Ultra-thin solar panels
In Hong Kong, bus operating company KMB is rolling out ultra-thin solar panels to generate renewable energy that supplies all electronic devices on board and recharges the bus.
#HongKong: KMB upgrades solar panel system on #buses which generates renewable energy that supplies all electronic devices on board “Green Reward Programme” to encourage passengers to ride on #solar buses with extra membership pointshttps://t.co/Cs3C0TZBbG pic.twitter.com/Hf209mRfDR
— CLondoner92 (@CLondoner92) September 1, 2023
Interior and exterior screens
Taking a look at the single-deck electric bus by Arrival, they have included display screens for the interior and exterior of the bus. It might be ideal to include the new zero-emission bus with information such as route information, service branding, real-time travel information, advertising, etc. You can read more on the Arrival bus display screens here.
The Arrival Bus brings to life our new method of design and production.
— Arrival (@arrival) December 28, 2021
We recently put the Arrival Bus through its paces at our proving ground track, a major milestone on our road to certification ahead of public trials.
The future of public transit #PoweredbyArrival pic.twitter.com/TAzUmTJsYr
Eink to rapidly change bus livery for different services
In my previous article from earlier this year, reviewing the launch of the Superloop express bus services, I suggested adopting Eink on buses.
A company from America named ‘Eink’ has invented new technology to change the colour of vehicles which is already used on the latest BMW i Vision DEE concept car. Perhaps this concept should be adopted on buses to make route branding more flexible without the need of repainting the bus fleet. This is the type of creativity I’d like to see for public transport.
The use of Eink on new zero-emission buses would certainly be ideal and enable the bus operator to change the livery of the bus without the need of repainting or applying new wraps. As mentioned in my Superloop article, the rapid change of livery would enable the vehicle to be used on different types of services, including bus rapid transit.
Number of doors and staircases
London commonly uses buses with two-doors and one-staircases. Buses outside of Greater London generally use one-door and one-staircase buses.
I have taken a look through various freedom of information requests made to local transport authorities on the ‘What Do They Know’ website about using dual-door buses.
“This batch of buses was specified with single door access because our roadside infrastructure is currently configured for single door buses as used by the current operators. The current ticketing system and ways of operation in the Liverpool City Region currently favour single door operation.
Consideration is being given to the role dual door buses might have to play in future in speeding journeys up and reducing dwell times. There is a need for this to be balanced with the need to both ensure roadside infrastructure is upgraded so it works safely and that mitigations are in place to minimise fare evasion, which can often be a challenge for dual door operations. We may be able to provide further information in future once the bus reform decisions are taken.”
Cambridgeshire and Peterborough Combined Authority stated:
Experience everywhere in Britain, except London, is that if the doors of a bus are directly in the sight of the bus driver, there are fewer platform accidents and fewer injuries to passengers than if passengers are alighting, or even boarding, through doors half-way down, or even at the back of the bus.
Warrington Borough Council stated:
The ZEBRA buses currently on order do not have two sets of doors specified. It is not our intention to order buses with two sets of doors as this is not appropriate for current bus operations in Warrington, or the layout of the bus interchange, which only allows access from the front, as is the case in many local authorities across England.
West Yorkshire Combined Authority stated:
In relation to the second point raised concerning why new buses are required to have single door, The Combined Authority has historically focussed on single door entry rather than duel because all ticket transactions need to go through the driver as well as the fact that the buses do not have a tap off facility, for contactless payments as many buses in London currently have.
In Singapore they have specified new double-deck buses with a three-door, two-staircase layout for their bus contracting model to improve commuter flow at bus stops.
LTA to Deploy Three-Door Double-Deck Buses from 2021
These buses are designed with a second staircase and an additional exit door at the rear of the bus to improve commuter flow. With an additional staircase, commuters boarding the bus will be able to access the upper deck via the first staircase while alighting commuters are encouraged to make their way down via the second staircase. The additional exit door allows commuters at the rear of the bus to alight without having to make their way to the middle of the bus.
Like all our newer buses, the three-door double-deck buses will be equipped with a passenger information display system to provide commuters with route-specific information, such as upcoming bus stops and the MRT and LRT lines near a bus stop. The buses will also have on-board audio announcements of upcoming bus stops to make commuting easier for visually-impaired commuters. The centre pole at the front door will also be removed to make boarding easier for parents with strollers. Wheelchair users will continue to board and disembark from the middle door of the bus, assisted by the bus captain deploying the ramp.
The minimum requirement for high frequency services should be two-doors and one-staircase to improve boarding and exiting flows at bus stops.
However, the number of doors and staircases varies for the type of services; I would suggest having multiple variants of the most accessible zero-emission bus. They are:
• One-door and one-staircase for long distance including express bus services.
• Two-door and one-staircase for medium to high-frequency routes to improve boarding and exiting flows at bus stops.
• Three-door and two staircases for Bus Rapid Transit and high-frequency routes, including multi-door boarding
TfL does mention the use of three doors from their Bus Vehicle Specification:
6.3 Minimising dwell time
The choice of the number of doors fitted to a bus shall be informed by an analysis of the effect of dwell time at typical bus stops on the route intended for.
London Buses generally operate a two door system with the entrance door forward of the front axle and the exit door between front and rear axle. When single or three door buses are requested, the front door remains unchanged, the centre door is deleted or duplicated at a specified area of the bus.
Last year I published an article revealing the dwell times of different types of buses in London. I’d also mention that TfL has made the three-door, two-staircase New Routemasters to front door only boarding to curb fare evasion.
Some examples of additional accessible features used elsewhere
Taking a brief look at the new zero-emission buses for Greater Manchester and Liverpool City Region, they have procured zero-emission buses with two wheelchair spaces, but they don’t have middle doors to improve boarding and exiting flows at bus stops, which London’s buses already have.In Athlone, Ireland, their single-deck electric buses have two spaces, one for wheelchair users and the other for buggy users. They also have second doors in the middle for passengers to exit the bus.
In Hong Kong, certain tri-axle buses contain two wheelchair areas. Bus operator KMB has provided information for wheelchair users on their mobile app named ‘App1933’ to remind the user of their next bus, and they inform the user if their next bus has two wheelchair spaces. These buses with two wheelchair spaces are mainly used on bus routes that serve the hospital, and they have the double wheelchair spaces sticker displayed on the windscreen of the bus.
The Singapore Government's GeBIZ had published a tender to procure new single-deck electric buses with two wheelchair areas and three doors.
#Singapore GeBIZ:
— CLondoner92 (@CLondoner92) April 17, 2023
Procurement of Single Deck #Electric Buses
Tender No. LTA000ETT23000025
Closing on 19 June 2023https://t.co/HMIIdlueEF https://t.co/LEH3NNB5w1 pic.twitter.com/aS6gLV1b4f
Comments about bus types
In my previous articles, I covered multiple freedom of information requests that revealed comments by bus users complaining about the Alexander Dennis BYD Enviro400EV City with high-specification interiors for routes 63 and U5, the Wrightbus Streetdeck Electroliner on route 119, and the Streetdeck Hydroliner on route 7.
I have also provided suggestions on how to improve bus designs in response to the comments revealed by the Freedom of Information responses by TfL.
Reviewing TfL’s Freedom of Information Releases: Upcoming London Bus Projects, New Routemaster Refurbishment, Further Comments about High-Spec Electric Buses and More… - (further comments about the high-spec buses on route 63).
Last year I published an article on the outcome of the Central London bus changes and I pointed out the bus users suggesting a specific vehicle type for their service.
On paragraph 4.5.2.4 in the consultation report, they have listed an overview of suggestions. 475 of the respondents suggested retaining/introducing Routemaster bus services, and 287 respondents suggested considering using low emission/electric buses. I guess they are referring to the three-door, two-staircase hybrid bus named New Routemaster.
I’ve thoroughly researched TfL’s Freedom of Information website and I’ve found further comments relating to the design of electric buses on different bus routes.
Routes 23 and C3 Optare/Switch Mobility Metrodecker EV
"A search of our Customer Service system has shown that during this period we received 43 complaints/feedback relating to the design or accessibility issues for the buses on routes 23 and C3."
Route 111 Wrightbus Streetdeck Electroliner
"Please see the attached PDF providing the 119 comments we have received concerning the new electric double-decker that replaced the New Routemaster bus on route 111 within the requested period, covering matters from design, accessibility and for example, ambience. In total, there were 112 comments that did not approve of the layout or design of the new vehicle model. Two of the complaints also used a standard template, both of which are highlighted in yellow for ease of reference."
I’ve taken a look at the various consultation reports on TfL’s Have Your Say website, and I’m amazed to see there are requests for zero-emission New Routemasters for double-deck routes and zero-emission tram-style buses for single-deck routes.
Silvertown Tunnel Bus Network Proposals
"Some of the top issues raised, either about the proposals in general or specific routes, were:
• Requests for us to use Zero Emission or electric buses on all three routes, with some specific requests for New Routemasters on routes 129 and X239 or tram-style buses on route 108"
Route 108 - Suggest using tram-style buses (such as Irizar le Tram)
Number of comments: 99
Routes 129 and X239 - Suggest using zero emission or electric buses, primarily new Routemasters
Number of comments: 273
Suggest using new Routemasters to make bus travel more attractive
Number of comments: 85
Suggest using electric and zero-emission buses for the Silvertown Tunnel in general
Number of comments: 51
TfL’s response:
“The Bus Action Plan commits to an inclusive customer experience which makes travelling by bus easy, comfortable and accessible to all. As part of improving the experience for customers when on buses, we have been trialling a number of features on route 63 and are soon to do so on route 358. Although we cannot commit to a specific vehicle type being used on routes 129 or X239, we do intend to incorporate what we have learnt from the trials on our network as we roll out new buses. This includes giving some further consideration as to whether route X239 should have a different name. However, we fully intend that all routes serving the Tunnels will be zero emission which is beyond the requirement of the Silvertown Tunnel Development Consent Order.”
The proposed route X239 has recently been renumbered to route SL4 as part of the Superloop network.
Improving Arthur Street for pedestrians and cyclists, and changes to 344 bus route
New electric or zero-emission Routemaster buses should be procured/used on route 344
Number of comments: 132
New Routemaster buses are more accessible with three doors and two staircases
Number of comments: 54
Improve design/colour scheme of buses
Number of comments: 13
Alperton and Stonebridge Park - Proposed changes to bus routes 79 and 83
Suggest using new Routemaster buses for double deck routes
Number of comments: 152
Suggest using single deck electric tram buses for single deck routes
Number of comments: 76
TfL’s response:
“We have a long-term plan for buses known as the Bus action plan. The plan commits to an inclusive customer experience which makes travelling by bus easy, comfortable and accessible to all. As part of improving the experience for customers when on the bus, we have been trialling various features on route 63 and are soon to do so on route 358. Although we cannot commit to a specific vehicle type being used the bus routes included in this consultation, we do intend to incorporate what we have learnt from the trials on our network as we roll out new buses”
Brent Cross buses – proposed changes to routes 102, 189, 210, 232, 266, 316, 326 and C11
Suggest using new Routemaster buses for double deck routes
Number of comments: 152
Suggest using single deck electric tram buses for single deck routes
Number of comments: 76
TfL’s response to the comments is the same as the Alperton and Stonebridge Park consultation.
I’ve read the Greater Cambridge Partnership’s - Making Connections 2022 consultation report and it has revealed there should be a future bus specification to improve accessibility, bus safety and the use of dual doors to improve boarding and the exit flows at bus stops.
Greater Cambridge Partnership - Making Connections 2022
Consultation report, May 2023
Frequency of comments in co-ordinated responses to the consultation questionnaire as identified in 10.2 of this report.
A future bus specification should be drawn up: this could include provision for cycles, flexible space to allow people to travel with pushchairs, mobility aids, wheelchairs, suitcases and shopping and with two doors for reduced loading/unloading times. New buses should also meet the Bus Safety Standard which has been developed by TfL to improve bus safety.
Number of comments: 13
To conclude, I believe my suggestions will help improve accessibility for bus services in London and elsewhere with high-spec interiors, additional wheelchair space, and various features to improve accessibility and convenience for passengers. This is one of my methods to encourage people to travel by bus.
My suggestions are not exclusive to one bus manufacturer. I’d like to see multiple bus manufacturers take my ideas on board to design and manufacture the most accessible zero-emission bus.
I also suggest transport authorities outside of Greater London should participate with TfL’s New Bus Specification to improve accessibility and boarding and exiting flows at bus stops for high-frequency services. This will also help local transport authorities to save money.
Use of bendy buses?
I’ve suggested on Twitter/X that the Superloop and East London Transit should use bendy (articulated) buses to increase capacity and improve accessibility. One of the risks is fare evasion, due to the open boarding arrangement which various cities around the world already have.
I do understand that the bendy buses are controversial due to their larger size affecting cyclists, pedestrians, etc.
Bendy buses are similar to trams but they have rubber tyres and are not on steel rails.
An idea! 💡
— CLondoner92 (@CLondoner92) June 9, 2023
Bendy buses may have been controversial buses for London.
I suggest #TfL should experiment with these new zero-emission tram-style bendy buses for the new #Superloop, along with new bus priority measures.
They are:
Irizar ie tram
Van Hool Exqui City
Hess LighTram https://t.co/4RQmqdG4uI pic.twitter.com/08GxvfNz6Z
Bendy buses may have been controversial buses for London.
— CLondoner92 (@CLondoner92) August 27, 2023
What if the tram-style bendy buses are used on the East London Transit services? https://t.co/IMSZ9tZy0k pic.twitter.com/Net7qaDna8
I’ve also talked about the use of bendy buses for bus rapid transit services in my article on reviewing TfL’s Bus Action Plan from last year (2022).
Accessibility is very important to allow the disabled, wheelchair users and older people, etc. to travel using public transport with ease, and to allow them their independence to travel. Hopefully my suggestions may help improve their experience of travelling by bus.
I invite you to follow me on Twitter/X by searching for @CLondoner92 or by clicking on the direct link to my Twitter/X page here. I'm also on BlueSky and Mastodon.
Previous articles detailing my suggestions:
• I believe it’s Time for a New Regional Transport Body for The South East of England?
• Why Inclusive Surcharge-free Data Roaming on Smartphones is Important for Overseas Tourists (& Vice Versa) to Navigate Public Transport, and To Purchase E-Tickets etc.
• I Believe TfL Should Reform The Travelcard Agreement To Offer Smart Flexible Ticketing Options
• TfL Should Allow Companies to Sponsor London Overground Lines to Improve Journey Planning and Increase Revenue