Use of longer buses in the UK: Regulatory Impact Assessment

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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:

The European Community (EC) sets down standards for vehicle construction to facilitate their international movement between Member States. EC Directive 2002/7/EC is mandatory on Member States as regards allowing the international operation of buses and coaches of increased length. The Directive contains a derogation for the UK (and Portugal) to maintain their current manoeuvrability standards until March 2005, during which time the European Commission has a duty to investigate the implications of the less stringent manoeuvrability standard laid down in the Directive.

The Directive will require the following maximum dimensions to be applied in Regulation 7 of the UK's Construction and Use Regulations:-

Bus/coach with two axles:

13.5 (was 12m)

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)

Two limited consultation exercises and a formal consultation, produced in accordance with the requirements of the Cabinet Office Code of Practice on Written Consultations, have been carried out in respect of increasing the overall length of buses and coaches, the results of which were predictable: Bus and coach operators welcome longer vehicles whilst Local Authorities are concerned about compatibility with road layouts, bus-stops and infrastructure.

Objective

To amend the Road Vehicles (Construction and Use) Regulations 1986 to implement the provisions of EC Directive 2002/7EC, which revises EC Directive 96/53/EC.

2(ii) Risk assessment

The UK considered these length increases would result in vehicles becoming potentially more dangerous due to rear swing out over pavements or into the path of oncoming and following traffic. A derogation from the new manoeuvrability requirements for 3 years was obtained whilst research is carried out by the Commission into the effects of the revisions. We have included a research project in our current program, which will contribute to the Commission's review. We are in the process of tendering for the research to be undertaken.

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 and re-configured 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 on which longer vehicles are needed to meet over-demand. Average prices for vehicles are £100,000 for a 12m single deck bus; £145, 000 for a 12m Double deck bus; compared to £140,000 for a 15m single deck rigid bus. An articulated bus costs £165 - 190,000.

Option 2: (i) Identify the Benefits

Reduced cost to government, of introduction of this mandatory change. 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 tighter manoeuvrability standards to an overall length of less than the full 15m) helping to curb congestion

(ii) Quantifying and valuing the benefits

This area of vehicle design has been regulated for many years so no data on accidents from vehicles with longer overhangs is available from which to estimate costs. No figures are available from the bus and coach industry to identify the number of vehicle journeys for which over-demand exists, which longer vehicles could meet.

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 introduced depends on a number of factors. However, operators believe that passengers prefer to be seated during a journey, but the effect of current accessibility legislation has been to reduce numbers of seats available on single deck vehicles or the lower deck on double deck vehicles. Longer vehicles offer the chance to redress this situation.

We have no data on routes where longer vehicles may be viable. The limited data we have indicates 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 considerably higher. Coach occupancy tends to be higher with, the scheduled services operating at about 75% capacity.

For buses the relevant costs to be considered are

Purchase Price:

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 vehicle 28 seat (German Mercedes Benz model) - 53 seat (UK design spec) which with seats + standing passengers = approximately 70 to 100 passengers total can be carried.

Double Deck vehicle 70 to 80 seats + standing passengers = approx. 100 passengers total can be carried

Single Deck 15metre 46 seat (German Mercedes Benz) + 87 standing passengers = 133 passengers total can be carried ( 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 15metre single deck.

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. No exact figures for businesses affected and staff involved can be ascertained as this will depend on the demand for the longer vehicles and as a result the number of vehicles that are manufactured. Also there is an unknown in respect of what routes the longer buses may be used on and how this will affect infrastructure changes.

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 conforming to the UK manoeuvrability derogation.

Significant costs on Highway Authorities for signing, bus stop lengthening and layout of stops.

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. Results of consultations

Two hundred and eighty eight organisations and interested parties throughout the United Kingdom were consulted on the draft regulations. This was achieved by a letter formally enclosing the draft Statutory Instrument and Preliminary Regulatory Impact Assessment Document. This package was sent out on 23 August 2002 and replies were required by 15 November 2002.

Those consulted included manufacturers and operators of buses and coaches and their trade organisations, highway authorities, the police. Organisations concerned with road safety, and those that represent bus and coach users were also included in the consultation, as well as other Government Departments likely to be effected by these changes.

We received thirty-six responses from the consultation of which nine had either no comments or accepted the proposals fully.

Eight of the respondees considered option 2 to be the correct way to implement these proposals. Six replies were concerned about the possible dangers that the longer vehicles may cause to other road users. Nine responses were concerned with the possible effects on road infrastructure.

Three replies were specifically in favour of or extending the time period of the turning circle derogation which the UK has in the directive, whilst five were not in favour of it or were concerned about it.

Two organisations were concerned about the effects that the longer vehicles would have on garages carrying out maintenance and testing in so far as the needs for more space and some additional equipment.

Two responses were concerned about the financing of the infrastructure changes that may be needed, and about enforcement.

There were eight other separate points raised.

The results of the consultation will be published through the inclusion of this document on the Department's website. All those who corresponded to the Consultation have been answered on the issues they took up.

9. 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 RIA.. Either option will have no more effect on some manufacturers or operators 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, and range of their products.

10. Summary and recommendations

The UK has to accept the longer vehicles set out in Directive 2002/7.

Option 2 (retaining current manoeuvrability requirements) will restrict the degree to which the increase in permissible length can be utilised, and hence the notional profit associated with more passenger capacity. However, the operating industry has not supplied any quantitative data in support of their contention that greater capacity is needed. The costs of Option 2 in terms of signage and necessary modification of highways infrastructure will be less than those for Option 1. In addition, the accident risk associated with Option 2 is less than that associated with Option 1.
Therefore, Option 2 is recommended to implement this mandatory Directive.

11. 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.

Regulatory Quality

I have read the Regulatory Impact Assessment and I am satisfied that the benefits justify the costs.

Signed by

David Jamieson
Parliamentary Under Secretary of State for Transport

Contact point: Malcolm Burch, Vehicle Standards and Engineering Division 5, Department for Transport, telephone 020 7944 2533.