t: 07516 185380
A voice for families of children and young people with special educational needs and/or disabilities
RBC post-16 transport policy and Equality Impact Assessment
Guidance from Reading Families’ Forum
Read the policy here: https://reading.govocal.com/uploads/f737bddd-6c0f-4be6-a1e3-c28dfb45dbf4/files/file/content/806b2068-98b6-4851-ac58-b1c78f271376/School_Transport_Appendix_A_Post-16_Transport_Policy_2027-28.pdf
There is statutory guidance about post-16 transport, which is government guidance that local authorities must follow. Read the statutory guidance here: https://assets.publishing.service.gov.uk/media/5c48534c40f0b616fba5cb6a/Post16_transport_guidance.pdf
RBC is seeking views on the policy. You can respond to the consultation here: https://reading.govocal.com/en-GB/projects/reading-s-post-16-transport-policy-consultation
The closing date is Monday 5th October 2026
RFF has set out some points families may wish to consider below under each of the consultation questions. The questions are in italics below, with RFF’s points underneath each one.
Proposal 1 - Annual Contribution
The Council is proposing to introduce an annual contribution that families would pay to Reading Borough Council for Post-16 travel assistance for sixth form students of:
-
£330 per term for families who do not qualify for the low-income contribution.
-
£175 per term for families who qualify for the low-income contribution.
The proposed contribution has been developed with reference to the cost of local public transport.
RFF is aware that charging will be unpopular, but recognises that there is no obligation on local authorities to provide free transport to those of sixth form age. There is, however, a duty to provide free transport to adult learners, which means young people aged 19+ when they start a new course. We understand that the proposed charges are only for students in school years 12, 13 and 14.
When responding to this question, you might want to consider the following points
-
A Reading Buses annual bus pass for age 16-18 costs £550. There is no explanation why the proposed contribution is so much higher.
-
The equality impact assessment suggests that there are bursaries available to help with transport costs. While there are bursaries, only some young people will be eligible for these and many will not.
-
Statutory guidance makes two specific recommendations about charging that RBC do not seem to have considered.
-
Where it is likely that a young person would be eligible for free transport under the adult transport duty, it would be good practice not to charge them a contribution for transport arrangements under the sixth form age duty. (Statutory Guidance para 37.)
-
As young people with special educational needs and disabilities are more likely to remain in education or training longer than their peers, any contribution sought from these families would need to allow for the fact they may have to contribute for longer. (Statutory guidance para 29e.)
Young people without SEND attending their local sixth form or college will typically pay less and for a shorter period - because mainstream sixth form normally lasts 2 years whereas special school sixth form lasts 3 years. It is therefore likely that this policy will directly increase costs for young people with SEND compared to those without SEND. The equality impact assessment does not consider this.
Neither the policy nor EIA consider the fact that very few students of sixth form age with an EHCP attend a mainstream school. This means that students have been placed by the council at a specialist placement and are unlikely to have been able to choose which placement based on how easy it is to get there. It may involve several buses or a long walk. It may be a considerable distance from Reading because of the lack of specialist provision locally. Most Reading sixth formers attend local schools and can travel there independently at a lower cost. Those with EHCPs are not so lucky. It is very disappointing that RBC wants to charge families a premium because of their lack of sufficiency for local sixth form places for SEND young people.
Proposal 2 – Educational Progression
The Council is proposing to introduce clearer criteria regarding what constitutes a new course for Post-19 learners.
A learner will normally be considered to be starting a new course where they are:
-
progressing from Entry Level 1 to Entry Level 2;
-
progressing from Entry Level 2 to Entry Level 3;
-
progressing from Entry Level 3 to Level 1;
-
progressing from Level 1 to Level 2;
-
progressing from Level 2 to Level 3;
-
progressing to a higher level qualification;
-
commencing a programme identified through the EHC Plan Annual Review as necessary to achieve agreed outcomes; or
-
commencing a new programme that supports Preparation for Adulthood outcomes.
Why this is important: a young person counts as “sixth form age” if they started their course before the age of 19. This includes young people in years 12, 13 and 14 (the third year of sixth form at a special school). If they start a new course after this, ie age 19 or older, they count as an “adult learner”. Different rules apply to these two groups.
RFF welcomes clarity for families on who is counted as of “sixth form age” and who is counted as an “adult learner”. However, we are concerned that the categories above may not be easy for families to understand and people may not know whether or not their young person qualifies under these criteria.
Proposal 3 - Eligibility Criteria
The Council is proposing a clearer eligibility framework to explain how applications are assessed.
For students with an Education, Health and Care Plan (EHCP) Sixth form aged (16 to 19) the following eligibility criteria applies:
-
The student is resident in the Reading Borough Council area.
-
The student has an Education, Health and Care Plan (EHCP) with a named school or is accessing education through an EOTAS package under s61 Children and Families Act 2014.
-
The named school or educational setting is the nearest suitable school or educational setting as defined in the Home to School Transport Policy and not a placement chosen on the basis of parental preference, AND
-
The programme of learning is full-time (i.e., at least 540 plus guided learning (planned and funded) hours per year, AND
-
The student is unable to travel on public transport to the educational setting due to their Special Educational Needs, disability or mobility difficulty, OR
-
The student lives more than 3 miles walking distance from the school or educational setting as measured by RBC, OR
-
The student is unable to walk the distance because of their mobility difficulty.
For students with an Education, Health and Care Plan (EHCP) aged 19 to 25 MAY be eligible if they meet these criteria:
-
be an adult aged between 19 and 25 years with an EHCP
-
live in the Local Authority area
-
be attending: a further education setting, an education setting maintained or assisted by the local authority and providing further or higher education (or both), an educational setting outside the further and higher education sectors, where the local authority has secured education or training and/or boarding accommodation for that learner
-
the educational setting must be named in the student’s Education, Health and Care Plan
-
the educational setting must be more than 3 miles away from the student’s home address, unless the student is unable to walk that distance because of their SEND, even if accompanied, or the route is unsafe
-
the student is unable due to their Special Educational Needs, disability, or mobility difficulty to use public transport independently.
RFF welcomes the attempt to clarify the eligibility criteria as the previous criteria have been unclear.
However, the criteria for 19-25 year olds are NOT eligibility criteria - they say a young adult MAY be eligible for transport if they meet these criteria. By law, the local authority must set out the actual eligibility criteria in their post-16 policy, and they have not done this. Families need to know what the actual eligibility criteria are for adult learners - aged 19-25.
We are also concerned that the proposed policy omits key criteria that appear in statutory guidance by restricting provision of transport to young people attending the nearest suitable school and not parental preference. This is in direct conflict with paragraph 29b of the statutory guidance: “Young people should have a reasonable opportunity to choose between the courses available to them at 16 and be supported to access their choices. Local authority transport policies must be supportive of reasonable choice. In defining what is ‘reasonable’, local authorities will want to take into account any complaints received in previous years in respect of local transport policy statements. We would expect reasonable choice to include enabling young people to choose courses outside their home local authority boundaries if it makes sense for them to do so. Local authorities will want to be mindful of neighbouring transport policies and consider how their own transport policy can support movement across boundaries. The transport policy statement should set out the local authority’s policy for travel to neighbouring local authority areas. Reasonable choice should also include enabling young people to choose an establishment of education or training that is not the closest to where they live if it makes sense to do so.”
The eligibility criteria also do not consider journey time as stated in paragraph 29d of the statutory guidance. “Journey time also needs to be taken into account. Young people should be able to reach their education or training without incurring such stress, strain, or difficulty that they would be prevented from benefiting from the education provided. For example, a young person should not have to make several changes of public service bus to get to their education or training, if that would result in an unreasonably long journey time. In this context, local authorities should consider which mode of transport will best meet the need to ensure a reasonable journey time. Good practice suggests that a child of secondary school age may reasonably be expected to travel up to 75 minutes each way to access learning. Local authorities should apply similar expectations to young people of sixth form age.”
This means that RBC must consider whether the journey is reasonable when considering whether or not to provide assistance. For example, if a young person had to travel from one side of Reading to the other on several buses to reach their educational setting, and this journey took over 75 minutes or caused significant distress to the young person so that they could not benefit from the education when they arrived, this must be taken into account, and not just the distance and whether or not the young person is physically capable of travelling it. The proposed policy makes no mention of this.
Proposal 4 – Personal Transport Budgets
The Council wishes to increase the use of Personal Transport Budgets (PTBs) where they provide a safe, suitable and cost-effective alternative to Council-arranged transport.
The Council is proposing that, for eligible sixth-form age students, a PTB will normally be offered as the standard form of travel assistance. Council-arranged transport would only be provided where a PTB is not appropriate..
Do you agree that a Personal Transport Budget (PTB) should normally be offered as the standard form of travel assistance for eligible sixth-form age students, with Council-organised transport only provided where a PTB is not appropriate?
RFF believes that this proposal will have a huge impact on families. RFF recognises that a PTB will work for some families but for many it will be a huge drain on their time and finances. This is because
-
The policy states that families will have to appeal if they do not think a PTB is appropriate. This suggests that the school transport team will not be assessing young people’s individual needs and the onus will be on the family to prove a PTB is not suitable. This is unreasonable when RBC will already know the needs of young people with EHCPs and will be aware that families arranging their own transport could be hugely expensive or complex.
-
The policy also states that PTB amounts are determined by the distance to the educational setting and are not expected to cover the cost of a door to door taxi service. This will leave the many families who do require a taxi, because they aren’t able to drive their own child and public transport is unavailable or unsuitable, considerably out of pocket. Eg a taxi to school may cost £20,000 per year but the PTB maximum is £5,000.
-
PTBs will be reduced if the young person is absent from school, attends part time, or attends short breaks. This risks leaving families out of pocket if they are having to contract with transport providers who may not refund these costs.
-
Unlike Wokingham who have adopted this policy, Reading is an urban area, and many people don’t have cars and rely on public transport. RBC encourages greener travel and wants to reduce reliance on private cars.
We encourage families to think about the impact of receiving a PTB instead of the council organising transport for the young person. Would you welcome this or would it leave you out of pocket? How would your young person get to school - what would the impact be on your family?
Proposal 5 - independent travel
The council is asking for your thoughts on how to support young people to travel independently. RFF has reminded RBC that some young people will never be able to travel independently because of their SEN / disability.
Proposal 6 – Application timeframe
We want to ensure families receive decisions about travel assistance as early as possible, giving them sufficient time to plan for the new academic year.
We are considering bringing forward the application and decision dates.
Bringing the timeframe forward would provide families with earlier confirmation of their travel arrangements before the summer holidays.
Which option would you prefer?
Option 1 – Current timeframe: Applications by 31 May, with decisions by 31 July.
Option 2 – Earlier timeframe: Applications by 30 April, with decisions by 30 June.
RFF has heard from many families who have been affected by the late decisions on provision of transport for this academic year. The fact that the council decided everyone in receipt of school transport needed to reapply created a huge amount of work for the school transport team, which surely was a contributing factor to the delay in informing families about the outcomes of this year’s applications.
RFF questions why families need to reapply every year if nothing has changed. This seems pointless - it creates additional pressure and stress on families and additional work for council staff.
RFF’s view is that decisions need to be made and communicated to families in time for families to appeal if they are not happy with the decision and receive the outcome of the appeal before the start of term in September. As the appeals process can take up to 60 working days (12 weeks) this would suggest decisions should be communicated to families by the end of May.
Overall Policy Clarity
Overall, do you think the proposed changes make the Post-16 Policy clearer and easier to understand?
RFF welcomes greater clarity on eligibility criteria for those of sixth form age but remains concerned about the lack of clarity on eligibility for adult learners. This contradicts the statutory guidance, which states (paras 24-25) that the post-16 transport statement must include: “who is eligible for transport support and how and when they should apply for support. Details of any concessionary fares, discounts, subsidies or travel cards should be included alongside the eligibility criteria for this support and how eligibility will be assessed. Additionally the policy statement must include full details of how a young person or parent can appeal if they disagree with a local authority’s decision and further avenues of complaint open to them if they remain dissatisfied following completion of the local procedure.”
RFF is also concerned that the language around reviewing transport arrangements in the policy is confusing and suggests transport may be withdrawn at any point if the LA wishes to do this. It would be helpful to clarify that transport is normally awarded for a full academic year (perhaps unless there is a change of home address), and all the references to reviewing at other times would be exceptional.
Reading Families’ Forum
24/9/2026