P-04-689 Improvements to the Railway Provision at Kidwelly Carmarthenshire. Correspondence – Petitioner to the Committee









1: Executive Summary

The Petition raises three main issues;


(a)  Wheelchair provision – the station platform on the west bound side is so low that wheelchair users can not get on or off the train, people with prams and other less ambulant people are also severely disadvantaged or unable to use the platform. This can be remedied either by raising the whole platform or more cheaply part thereof by a “Harrington Hump”.


(b)  The station is a request stop – this is anachronistic and potentially discriminatory for those who are blind or visually impaired and for many non-disabled people acts as a deterrent to using the station. Anecdotally there is, (well known locally) evidence of people at night when there is no visible guard being carried on past Kidwelly, which has engendered a reluctance to use the train for fear of this occurring.


(c)  The service provision from Kidwelly is poor, which reduces the station’s effectiveness and does not properly meet local needs for leisure or travelling to work. (For example returning from Cardiff at commuter times there are only direct trains at 17.04, then 19.46 and 21.04, which is simply inadequate and does not serve the needs of commuters or shoppers). There are however a number of trains to and from Carmarthen, which pass through Kidwelly without stopping, which if they stopped would enhance the service with seemingly limited impact upon the train operator.


2. Background


The service provision at Kidwelly has been a long running source of local discontent and complaint as evidenced by the regularity it appears in social media threads and in references / complaints by the community to local Councillors and the local MP.


The issue was sufficiently pressing, controversial and topical locally for representatives of the local Town Council to ask to meet with Arriva to discuss the issue in November 2015.


Further, following lodging of this petition a meeting was convened by myself with Arriva Trains Wales at which the local community was represented by myself, the Local MP Nia Griffit , (then shadow secretary of State for Wales), the then AM candidate, now AM for the area Lee Waters and the local County councilor, Ryan Thomas. This broad level of representation across all representative bodies is a powerful indicator of the strength of local feeling about the issues raised.


3: Demographics and Social need


The demographics of Kidwelly, (which in assessing service provision it should be remembered is officially designated as a town), show an 8.9% rise in population between 2001 and 2014 with a population density of 285 people per square kilometre.


Socially it has the higher proportion than the average number of people over 45 in Carmarthenshire with additionally a higher proportion of people with long term limiting illness than the Carmarthenshire average.


Economically the median CACI’s “Paycheck” data shows an estimated median household income of £21,852, which is 17th lowest in Carmarthenshire with a higher than average levels 5-6 occupations (lower supervisory and technical oc

 -source Carmarthenshire County Council, ward electoral division profile. http://www.carmarthenshire.gov.wales/media/1221214/Kidwelly_Ward.pdf)


 Kidwelly has a limited number of major employers in the Town and anecdotally therefore many people, who are in work of necessity commute out of town. The train being the major public transport provider for those dependent on or for environmental concern reasons wishing to use, public transport.  In this context it is of note that the local bus service ceases running in the early evening.


In leisure terms, especially for young people the train is of significant importance.


Additionally, Kidwelly has an arguably currently under developed tourist trade with the CADW maintained and historically significant Kidwelly castle and the natural resource of the Quay area, with the world’s oldest recorded industrial canal system created by Thomas Kymer, both within walking distance of the station.


-          see discovering Carmarthenshire



Further the Gwendraeth Valley Railway Society has recently received a major Westminster government grant to develop the UK’s first velorail, which is to be based in Kidwell and which will be a major tourist attraction in the very near future and which will both require  a proper rail provision to the town and benefit the rail operators by increased usage.


-see ITV report



There is therefore a compelling argument that given both the social and demographic needs of the area and the potential and actual tourism benefits to the area for an effective and improved local rail infrastructure, as the current provision is neither serving the need, able to deal with the potential and by its nature is almost certainly deterring usage numbers.


The lack of provision is therefore impacting negatively socially and economically and adversely affecting the community and Town Council’s desire to encourage local growth and regeneration.



4: Inadequate provision for disabled and other passengers with difficulties and needs.


The platforms at Kidwelly are so low, especially on the west bound side that wheelchair users, those with mobility aids and other less ambulant passengers plus those with prams or small children can not get on or off trains. The standard mobile ramps on the trains are too steep to be used either safely or at all.

The relevant legal provisions governing theprovision of accessible public transport are set out in Part 12 and Schedule 20 Equality Act 2010 and also (currently at least), in EU law as it relates to railways specifically Directive 2008/164/EC, which applies Europe-wide standards of rail accessibility; and Regulation 1371/2007/EC on rail passenger rights and obligations.


In addition this Petitions Committee will be familiar with the public sector duty to promote equality also set out in the Equality Act 2010, which applies to the workings of the committee and the Welsh Assembly.

Further all rail and station operators are required to produce and publish  a Disabled Person’s Protection Policy (DPPP).


DPPPs are also proscribed by the rail regulator (ORR) in Condition 5 of the passenger and station licences issued under section 8 of the Railways Act 1993, as amended.

In respect of Arriva Train Wales their DPPP states:


“We have, and maintain, a working matrix (database) of all stations detailing where facilities do (or do not) comply

with the Code of Practice, where each station requires works to be undertaken to make them accessible and whether


or not it is physically feasible to undertake this work. This matrix is regularly reviewed and is used to pinpoint areas

which would benefit from specific accessibility schemes.”


Further it also states:

"Subject to funding availability, Raised Platform Humps will be installed at

stations where access to trains currently presents difficulties but where

it would prove difficult to raise the height of the platforms." 


The provision at Kidwelly, therefore on its face is potentially discriminatory under the relevant equality legislation, by imposing a provision or practice that putsdisabled people at a substantial disadvantage, by virtue of the inability to access public transport by boarding or alighting from trains at this station.


The duty to make reasonable adjustments in the Equality Act 2010 is an anticipatory duty, which should be proactively acted upon and therefore the operators of the relevant transport provision especially as clearly aware of the issue in general terms from their own matrices and in specific by virtue of this and other complaints and as such are bound to take reasonable steps to eliminate or ameliorate the position.

(Further, albeit outside of the ambit of the disability discrimination legislation, other passengers including the elderly, those with prams, children and heavy shopping struggle and at times are also unable to board or alight trains at Kidwelly and are not only disadvantaged and upset by this, but also positively deterred from using the rail service or indeed are unable to use the service)..

Reasonable Adjustments

Having identified a disadvantage the question thereafter becomes what are the potential and practicable reasonable adjustments.


In respect of Kidwelly, it is clear that this problem could be ameliorated in part by the provision of a so called “Harrington Hump”, this would involve raising a part, if not whole of the platform to a level at which the train could be accessed and allow a sufficiently gentle run off for wheelchairs to use the platform.


Whilst not a whole solution as only part of the train will be accessible and will require some signposting to ensure wheelchair and other less ambulant users are in the correct part of the train, this would go a long way towards ameliorating and reducing the discriminatory effect of the current platform provision.


As this is an adjustment that has been made at a number of stations throughout the UK, it is by definition a practical and reasonable adjustment.


Your petitioner has personally had experience of arriving in Kidwelly as the carer of my step son to be told unless he could get out of his wheelchair we would have to go on to Carmarthen and sort out with the station staff there a taxi back.  


It seems therefore that accessing Kidwelly by train as a wheelchair user is only possible if the wheelchair user has pre-booked his or her train to Kidwelly and then overshoots the stop and goes on to Carmarthen and get a taxi back.


This it is contended is not a reasonable adjustment as it adds time, inconvenience and embarrassment and acts as a barrier, (possibly an unlawful barrier), to disabled service users. Further, those seeking to travel at unplanned or variable times are at best disadvantaged and at worst debarred from the service and those with no prior knowledge of the service are completely disadvantaged. Further given the availability of the Harrington Hump as a rrmedy is also unreasonable by virtue of the option of better more appropriate measures.


5.  Request Stop.


The service at Kidwelly is also, in large part, a request stop which causes problems and confusion including for the blind and those who do not know the area. Again the provision may fall foul of the Equality Act 2010’s requirements upon yourselves.


There is an active and real fear based in part upon local anecdotal knowledge of previous incidents of not being seen and trains passing by or of being unable to attract the driver's attention and being carried past the stop.


 This is exacerbated in the evenings when many trains do not have or do not appear to have conductors and there is again clear anecdotal evidence of a people missing the stop engendering a reluctance to use the service.


Those from outside the area often greet the suggestion that the stop is a request stop with disbelief and again this does not create a positive impression on potential visitors that Kidwelly is a town with significant tourist attractions.


The arguments utilized against the making of Kidwelly a regular stop and indeed enhancing the service provision are seemingly based upon timetabling constraints and passenger numbers. I will deal with these in turn.




In respect of a standard stop, I understand that approximately a 3 minute period is generally the norm, whereas in respect of Kidwelly a 30 second halt is programmed in on the basis that the train operator gambles that not all request stops will be utilised on any given day.


Clearly however the stopping of the train at Kidwelly occurs on a regular basis and can therefore self-evidently be accommodated within the operating logistics of the line. Any argument to the contrary being logically untenable as in theory ever train could be hailed and this must be accommodated for and in practice there seems no evidence that being hailed and therefore stopping at Kidwelly has caused operational difficulties.


Further a preliminary analysis of the “working timetable”, the operators’ actual running timetables, which details potential variances and non station stops and timings, as opposed to the published public version, would seem to support the argument that there is a facility to make up any “lost” time over the running of the line.


-          See relevant working timetable




I understand also for example that there is often a two minute halt outside Llanelli, which could potentially be used to accommodate any time issues.


I also note that Gowerton has been changed from a request stop to a standard stop with seemingly no issues arising.



The passenger numbers fallacy



On review the ORR figures for Kidwelly (with one small exception), reveal a substantial year on year increase in usage from 8,867 to 31,040.


-          See ORR site



Given the ongoing growth in population in the town of Kidwelly and the tourist developments referred to above this increased usage trend is virtually certain to continue.


In any event any argument based simply upon current recorded passenger numbers is both flawed and fails to take account of the full picture in that, the recorded numbers, (assuming accuracy),  is a self-serving and circular argument. A poor irregular often request service, which does not meet commuter, business, tourist or social needs means potential passengers have been forced to find alternatives, thereby reducing recorded numbers.


 Anecdotal but often repeated evidence clearly suggests large numbers of people will drive or use other public transport to make their way to Swansea, Llanelli or Burry Port to take advantage of the increased stopping train numbers. (A similar number of trains passes through Kidwelly, but not all stop), and to avoid the inconvenience and issues of the request stop.

 Simply put a poor service negatively skews passenger numbers, whereas a better service which can be relied upon would generate greater use and more passenger numbers.


In any event, whatever the validity of current or future numbers arguments there is an overriding social and economic service provision need here in Kidwelly, which outweighs mere (potentially flawed), statistical arguments.



6. Additional timetabled stops


As set out above a number of trains pass through Kidwelly without stopping en route to and from Carmarthen and Swansea.


At the risk of repetition, the needs of Kidwelly are such that an improved service is justified and this could / would be easily served by the simple expedient of stopping those trains that already run through the station at the station.


This requires no additional trains to be run or additional rolling stock, but merely a minor timetabling alteration to the existing provision a compelling balance in favour of taing such a step on any cost benefit analysis.


7. Conclusion


Your petitioners therefore request that the Committee with the minister and the assembly give positive consideration to the request made and use their best endeavours to achieve your petitioners desired outcomes, namely; 

(i)           an accessible station,

(ii)          (ii) removal of the request stop and

(iii)        (iii) additional provision by stopping those trains currently passing through the station without halting.






Philip Thompson

Your Petitioner

(Kidwelly Town Councillor)