The Road Vehicles (Construction and Use) (Amendment) Regulations 2003

1. Title

Consultation on an amendment to the Road Vehicles (Construction and Use) Regulations 1986 to permit the use of longer buses in the UK in accordance with EC Directive 2002/7/EC

2. Purpose and Intended Effect of the Measure

2 (i)The Issues and Objectives

Issue:

EC Directive 2002/7/EC is mandatory as regards allowing the operation of longer buses but contains a derogation for the UK to maintain their current manoeuvrability standards whilst the effectiveness of those laid down in the Directive are investigated by the Commission.

Two limited consultation exercises have been carried out so far in respect of increasing the overall length of buses and coaches. The results of which were predictable. Bus and coach operators want longer vehicles and Local Authorities are concerned about compatibility with road networks

The Directive will require the following dimensions to be applied in Regulation 8 of the Construction and Use Regulations:-

Bus/coach with two axles:	increase from 12m to 13.5m
Bus/coach with more than two axles:	15m (was 12m)
Articulated bus:	18.75m (was 18m)
Bus drawing a trailer:	18.75m (previously omitted from regulations)

Objective

To consult on the draft amendment to the Road Vehicles (Construction and Use) Regulations 1986 implementing the provisions of EC Directive 2002/7EC, which revises EC Directive 96/53/EC.

Options

Option 1: Introduce longer vehicles without existing strict controls on manoeuvrability.

Preliminary research has shown that relaxation of current manoeuvrability standards will make the vehicles incompatible with existing road layouts and increase risk of injuries to pedestrians and other road users.

Unsuitable areas and roads will probably have to have access legally restricted and signed. Bus stops and parking areas will have to be enlarged to suit longer and less manoeuvrable vehicles.

Option 2: Introduce longer vehicles with existing controls on manoeuvrability. Fewer roads would need to have restrictions for the longer vehicles. Danger to pedestrians and other road users reduced compared with option 1.

Requiring longer vehicles to meet the existing requirements may increase the technical complexity of steering systems for the longest vehicles and may restrict the maximum possible length to below the new legal maximum (15m). Vehicle operators claim that potential reductions in costs through more efficient larger vehicles will have been lost. They may also claim that they will be put at commercial disadvantage when operating in Europe to operators based in other EU Member States.

Bus stops and parking areas will have to be enlarged to suit longer vehicles.

3 (ii) Issues of Equity and Fairness

Four groups will be affected:

(a) UK local and Highway authorities
(b) UK based bus and coach operators
(c) Overseas coach operators
(d) UK and Overseas Manufacturers

Option 1

(a)The local and highway authorities will have to bear the cost of assessing the suitability of roads for the longer vehicles and of setting up and enforcing longer bus stops and any area dedicated to buses. They will also have to bear the cost of the regulatory procedure and signing of restricted access areas.

(b) & (c)UK and overseas operators will enjoy fair competition both in UK and overseas.

(d) UK and Overseas manufacturers will not have to accommodate extra criteria in their designs.

Option 2

(a) UK local and Highway authorities costs will be limited to those associated with the introduction of longer buses (extended bus stops and parking bays) but assessment of suitable roads will be less than those in option 1.

(b) and (c) UK based operators will effectively be restricted to smaller vehicles than their competition when operating on the continent. Overseas operators will have to select specific coaches from their fleet when operating in UK.

(d) To sell in the UK market manufacturers will have to design for the stricter manoeuvrability criteria.

4. Benefits

Option 1: (I )Identify the Benefits

Reduced barrier to free movement of passenger vehicles between UK and Europe. Increased capacity per vehicle (up to 25%) helping to curb congestion. Complete alignment of UK regulations with European, simplifying the design, build and operation of buses and coaches

(ii) Quantifying and Valuing the Benefits

No figures are available from the bus and coach industry to identify the number of vehicle journeys for which over-demand exists. Average prices for vehicles are £100,000 for a 12m single deck bus; £145 000 for a 12m Double deck bus; £140,000 for a 15m single deck rigid bus; £165 - 190,000 for an articulated bus.

Option 2: (I )Identify the Benefits

Reduced cost to government, of introduction. Maintenance of existing safety levels for pedestrians and other road users. Reduced risk of damage to road infrastructure. Increased capacity per vehicle (up to 16% rather than the 25% in option 1 because vehicles may be restricted by the design needed to meet manoeuvrability standards to an overall length of less than the full 15m) helping to curb congestion

(ii) Quantifying and Valuing the Benefits

No figures are available for potential injury costs as this area of vehicle design has been regulated for many years so no estimate of potential accidents from vehicles with longer overhangs possible. Calculation would utilise the following pattern. Likely cost-savings to government nationally are of the order of If a figure of X pedestrian injuries with an average of £Y per injury treatment (excluding the consequential costs following a fatality) is assumed then the savings would be No figures are available from the bus and coach industry to identify the number of vehicle journeys for which over-demand exists.

5. Compliance Cost for Businesses, Charities and Voluntary Organisations

The derogation maintaining the existing criteria of manoeuvrability was a result of concern to avoid an increase in risk of injury to pedestrians and other road users, and to remove the need for expensive road layout alterations and/or legislation and signage to restrict use. The risk of injury will be related to the number of longer vehicles entering service. Road alterations or restrictions would be independent of numbers of vehicles.

The possibility of longer vehicles actually being used depends on a number of factors. Operators believe that passengers prefer to be seated during a journey, but the effect of current legislation requiring a low floor and wheelchair access is such that the numbers of seats available on single deck vehicles or the lower deck on double deck vehicles is limited.

We have no data on routes where longer vehicles may be viable. The limited data we have indicated that AVERAGE passenger loads are quite low, something in the region of 13 passengers per vehicle for buses in urban areas. Peak loads will be noticeably higher. Coach occupancy tends to be higher with, the scheduled services operating at about 75% capacity.

For buses the relevant figures that will have to be considered areApproximate Cost:

Single deck 12m	£100 000
Double deck 12m	£140 000
Single deck 15m	£145 000
Articulated bus 18m	£165 - 190 000

The approximate carrying capacities are (seating configuration varies significantly according to operators)

Single deck 28 (German M Benz) - 53 (UK spec) seats + Standing = approx. 70 -100
Double Deck 70 - 80 seats + standing = approx. 100
Single Deck 15m 46 (German M Benz)+ 87 Standing = 133 ( it is estimated that it may be possible to put up to 70 seats in a UK specification vehicle with reductions in standees)
Articulated bus - approximately the same as the 15m.

The only apparent advantage shown by the 15m vehicle is that of the single deck over the difficulties / reluctance of passengers in using the upper deck.

5 (i)Business Sectors Affected

Bus and coach operators; bus and coach manufacturers; local authorities/highway authorities.

5 (ii) Compliance Costs for a "Typical" Business

Option 1: No Costs on Bus and Coach Operators

UK Bus and coach manufacturers would have no greater costs than others to develop 15m vehicles

Significant costs on Highway Authorities for signing.

Option 2: No Costs on Bus and Coach Operators.

Bus and Coach manufacturers would have no extra cost when producing vehicles up to around 14m. Longer vehicles up to 15m would incur greater development costs as alternative solutions to the manoeuvrability requirements would have to be found.

Low cost on Highway Authorities as minimal signing required.

6. Small Business Litmus Test

The effect of the implementation of this measure are likely to mirror those mentioned in 5(ii) above but on an appropriately smaller scale relevant to the size of the business.

None of these options will have any impact on small businesses.

7. Other Costs

Local Authority costs of restricting access to unsuitable roads, repair of road infrastructure. Health service costs associated with pedestrian and vehicle collisions. Impact of accident reporting on public perception of public transport safety.

8. Competition Assessment

An assessment of the likely effects on competition (using the 'competition filter') has concluded that there will be no detrimental effect on competition as a consequence of either of the proposed options set out in this PRIA.. Either option will have no effect on some manufacturers or operators more than others or have any effect on the number or size of them. There will be no higher set up or ongoing costs for any manufacturers or operators entering this market. Rapid technological change is not a characteristic of this market. Either option will have no restriction on the ability of manufacturers or operators to choose the price, quality, range of their products.

9. Summary and Recommendations

The UK has to accept longer vehicles because of the Directive. The Directive will not impose costs on either the vehicle operators or manufacturers as the choice of using or producing longer vehicles will be theirs. The option to allow the longer vehicles with the relaxed manoeuvrability standards will result in highway authorities having to examine their road networks and probably applying restricted access to these vehicles. Retaining manoeuvrability standards will most likely result in a lower capacity vehicle with associated lower profit margin for operators. Neither of these costs can be quantified, and the operating industry has not supplied any data to show what the perceived benefits of the longer vehicles are.

10. Enforcement, Sanctions, Monitoring and Review.

Option 1 No additional enforcement on vehicle and operator, but enforcement of restricted access areas required.

Option 2 Enforcement on UK operators easy through current PSV operating licence procedures.

Enforcement on overseas coach operators is difficult.