Correct, it may well not make total sense ! - not all laws do.....
Indeed.
My suggestion would also have the advantage, where coaches used aren't accessible, of stopping coach companies taking the mick by putting in phantom stops (that people don't actually use[1]) to allow them to slyly register the coach service as a local bus service and claim BSOG.
If that game was wanting to be avoided, a low *floor* requirement for local bus would make sense - also giving the benefit of better accessibility for those other than wheelchair users (a wheelchair lift, depending on design, may be useless for someone who uses crutches or a walking frame, for example). It might also give motivation to the industry to design a genuine low-floor coach in the manner of German Schnellbusse, which might work well on things like the UCOC X5 (though not so much on a genuine long-distance coach service where luggage provision would not be adequate unless it was a double-decker with a short lower-deck section for those with access issues).
[1] Or maybe they do. The MK-Luton Stagecoach 99 has two such stops, at Kingston Roundabout in MK (not the Kingston Centre, just an odd bus lay-by) and at the first signed stop off the M1 at Luton, for exactly that purpose. It has turned out that at certain times of day (warehouse shift changeovers) these two are the busiest stops on the route by far. So I suppose there are benefits - I expect were they not needed for that purpose those stops would never have been considered.
