Bus Services (Wales) Bill: Our response

Title of consultation: Bus Services (Wales) Bill

Source of consultation: Climate Change, Environment and Infrastructure Committee 

Date: 13 May 2025

The Equality and Human Rights Commission is the equality regulator for Great Britain and National Human Rights Institution for Wales and England, and reserved matters in Scotland. We have a statutory mandate to advise the Welsh Government and the Senedd on matters relating the equality and human rights.  

Our Strategic Plan and addressing barriers to accessing services

We wrote to the Chair of the Committee on 26 March 2025 to update on our new Strategic Plan for 2025 to 2028. This is relevant to your work on the Bus Services (Wales) Bill (the Bill), especially in relation improving access to public services. 

Part of our Strategic Plan is about strengthening participation in society by removing barriers to key public services. This includes addressing the challenges faced by protected characteristic groups, such as older and disabled people, when using bus services.

We welcome the opportunity to engage with a Bill that seeks to modernise bus services for all. An important indicator of the success of this Bill will be a transport system that is accessible and meets the needs of older and disabled people.

Our research

Our 2020 research report Accessible public transport for older and disabled people in Wales found that older and disabled people face a broad range of barriers to travelling independently in Wales. These barriers affected their ability to live independently, including access to services and opportunities to socialise with others, which then negatively affected their physical and mental health.

Older and disabled people highlighted several barriers that restricted their opportunities to travel by bus. These included:

• digital exclusion in the move to online journey planning
• inaccessible information
• staff awareness and training
• lack of enforcement of priority seating
• wheelchair users and people with visual impairments being denied access
• variability in the design and quality of bus shelters across local areas, including the shelter provided, suitable seating and delivery of real time information
• bus stops were often in inappropriate locations

We found that equality considerations for older and disabled people had not been fully integrated into regional and national strategies and policies. Public bodies responsible for transport planning had not used the Public Sector Equality Duty (PSED) and Wales specific duties to address inequalities in transport. This could be seen by the lack of objectives, interventions and actions to address the most pressing and persistent inequalities in public transport.  

Our research sets out the steps we would expect public bodies developing transport planning to take to create an accessible and inclusive public transport system in Wales. This includes complying with the PSED and applying conventions such as the Convention on the Rights of Persons with Disabilities (UNCRPD) in transport strategies. The research sets out how public bodies can use the PSED as a tool to plan services to meet the needs of users. We seek assurances that the PSED, regulations and legislation in relation to equality and human rights will be adhered to as part of the Bill, and any following policy development and legislation.  

Our advice on the Bill

As it is currently drafted it is not clear how the Bill will embed equality and accessibility. While Section 4 of the Bill requires Welsh Ministers to consider accessibility of local bus services as part of the six objectives. Detail of how statutory obligations will be met should be provided in the Bill. 

The Bill will give responsibility for the design and planning of bus services to the Welsh Government, Transport for Wales, local authorities and Corporate Joint Committees to plan and design bus services. 

Each of these public bodies are subject to the Public Sector Equality Duty (PSED). The PSED places duties on public bodies to have due regard to the need to eliminate discrimination, promote equality of opportunity and foster good relations. Listed public bodies also have a duty to pay due regard to socio-economic disadvantage in their strategic decisions through the Socio-economic duty (SED), which could be an additional lever in the Bill. 

The Bill would be strengthened by embedding equality, accessibility, the PSED and the SED. Placing clear duties on the public bodies designing and planning bus services to tackle the barriers faced by users will support the Welsh Government’s ambition for achieving an accessible transport system. These duties would provide important steps to ensure that bus services are designed to meet the needs of older and disabled people, along with supporting public bodies to comply with their statutory obligations.

We will engage with the Welsh Government on the development of the Bill and seek clarification on how they will meet their ambition of an accessible transport system as committed to in the ‘Travel for all’ statement on 1 April 2025.

The Committee should seek clarification in their scrutiny of the Bill on how it will meet the diverse needs of Wales’ population and ensure buses are accessible for all who want to travel. 

We would also welcome further discussions with the Committee and the Welsh Government, and offer our advice on the equality and human rights implications in the development of the Bill. 

wales@equalityhumanrights.com