This special edition Member Alert comes to you from Day 1 of the BIC Bus Industry Summit in Canberra (28 June 2022). It reports extensively on (most of) the presentations heard today:
- Keynote speech – Summit opening
- Reform of the Disability Standards for Accessible Public Transport
- Reform of the Heavy Vehicle National Law
- The ‘no bullshit’ reality for the bus industry in the race to zero emissions
- E-Mission Zero – an operator’s roadmap to zero
Keynote speech – Summit opening
The Summit was opened by Senator the Honorable Don Farrell, Minister for Trade and Tourism. It’s nice to see a South Australian senator talking to the very crowded room and giving the opening speech. To give you an overview of his speech, the Minister spoke of…
Domestic and regional tourism springing back to life, people are regaining their confidence. While we know the recovery is underway, there are plenty of challenges to getting tourism restarted. The new government is hugely aware of the challenges being faced by the transport and tour sector. Interestingly, Prime Minister Albanese’s longest portfolio was transport – we’ve never had a PM with so much knowledge of transport, which is a good thing for our industry.
We are facing labour shortages – and the Government recognises these issues and is trying to address them. In tourism, $10 million has been allocated for marketing and other initiatives to attract people back to the industry.
They are looking at better ways to engage more workers such as young people, mature workers and people with disabilities. Pleased to see that BIC is leading the charge with promoting transition towards zero transmission vehicles, and vehicle accessibility for people with disabilities.
And finally, nice for us South Aussies, he also gave the Clare Valley and its red wines a plug.
Reform of the Disability Standards for Accessible Public Transport
Madonna Woodhead – BIC
Since July 2020 Bic been involved heavily in the transport standards reform. There are 11 focus groups in the review of disability standards and the BIC is involved in 9 of them, they formed a DPSAT review committee in April 2021.
There will be 40 reforms relating to bus and coach. There will be updates to 29 existing sections of the standards and 12 new reforms are proposed. There will be challenges for small to medium operators. Biggest impact will be the removal of exemptions for school buses. The desired position on the reforms is that every school bus will be accessible. But for many operators that is not possible because of things like:
- variables to pick up and drop off
- seating capacity loss in vehicles (e.g. 24-seater high floor bus would lose 6 seats. 56-seater high floor would lose 16 seats if converted to a low floor)
- ability of bus to travel on highways at speed.
The BIC has negotiated heavily for a different position – if you want to involve school buses they want to see a compromise. BIC wants to minimise any regulatory changes to vehicle design.
The estimated timeline – ministerial decisions in 2023 around reforms and whether they will apply to existing assets or new assets ongoing. Probably coming into law around 2025.
Reform of the Heavy Vehicle National Law
Aaron de Rozario – National Transport Commission
In May 2021, Ministers approved a safety and productivity reform program that covers 6 key areas:
- Operator assurance
- Technology and data
- Duties and driver health
- Fatigue management
- Vehicles and access
Objectives and principles of where they want to take the law:
- A simpler, outcomes focused law – safety and productivity being the desired outcomes
- A better operator assurance scheme that – more comprehensive and encourages investments in safety and productivity
- A better audit regime that addresses ‘multiple audit’ concern
- A regulatory environment that provides certainty for operators that want it, and flexibility for those that need it
- A law that encourages active risk management – thinking about safety in an an active way so the outcome is operators working safely not just ticking boxes
Operator certification: build certification around a core safety management system principle. Make sure in the Regulation that modules can easily be created (so the system is easy to expand on). Create fatigue, mass distance location (MDL) and vehicle maintenance modules. Offer greater flexibility for alternate compliance options (e.g. operators using technology in different ways). A robust and consistent auditing regime.
**Important for the bus industry – if developing systems for safety management, make sure they are well aligned between States. Industry should think about what’s important for the bus industry – what are the benefits of certification that would be specific to the bus industry?
Technology and data: Want to resolve issues and create framework that says if an operator invests in and installs approved technology (i.e. fatigue management) they should know what that data will be used for and how it will be used. Also, technology should be certified, if the operator invests they know that the tech meets the requirements of the heavy vehicle law.
Duties and driver health: Clarify Chain of Responsiility (CoR) definitions to make sure they reflect policy. In other words, many rules affect drivers and operators, but sometimes there’s someone like a vehicle repairer with a job that reflects on the safety of the vehicle (e.g. tyre changing). There may be a possibility to legislate it so that suppliers like this are legislated to do things in a certain way, therefore making CoR less complicated. Also, fitness to drive requirements may be expanded – looking at areas such as sleep apnoea, cardio vascular disease and diabetes.
Fatigue management: They are discussing a 2-tier fatigue management system. Tier 1 would be a general schedule. Tier 2 would have more flexibility for operators with certified safety management systems (mentioned above under technology and data). A new general schedule is under discussion – they want the new system to encourage electronic record keeping.
Vehicles and access: Aiming for a national online access system (e.g. a national-controlled bus network) and improvements to performance-based-standards (PBS) processes. Considerations for the bus industry are – mass, height and length considerations; PBS as it applies to buses; bus design for Euro VI and electrification and impacts on mass and definitions.
The National Transport Commission will continue engaging with the heavy vehicle industry – including with the BIC – to make sure that bus is heard and included in the regulatory changes.
The ‘no bullshit’ reality for the bus industry in the race to zero emissions
Stephen Lucas – Chair BIC’s Zero Emission Bus Committee (and Bus SA President)
Buses travel about 2 billion km annually in Australia – if they could run at zero we would need a vast increase in power, and what about the supporting infrastructure? How are we to do this as a nation? It is going to require government intervention. The amount of renewable energy we are going to need is huge. And we are going to do this at the same time as reducing coal and gas – which currently makes up 70% of power in this country.
So why is the bus industry the canary in the coalmine?
It makes sense because our industry relies on definable outcomes. But we need education and training. How we train drivers, the public, first responders and operators has to be nationally consistent. Manufacturers need more (and better) regulations and standards to deal with new technologies without excessive burdens on our bus building industry. Contracts that we currently have are not fit for purpose in a zero environment.
Also, the infrastructure for hydrogen is huge. A refuelling station is millions of dollars. We need to work with government to find a pathway forward to work out how this will be funded. Industry and government has to build an open and transparent relationship to get the outcomes that we seek.
Most importantly, we need federal government energy policy that supports what we are trying to do. Our industry needs to lobby government effectively about energy policy.
We need state policy that will show the way forward. There needs to be an open book approach with government about whole of life costs – we shouldn’t hide from it – we need real metrics of what success looks like.
The approvals process takes a long time – so we need government on board with this.
There is also a need for social licence, meaning that people are generally supportive but they don’t have enough information. They need to understand what it is and what it means to them.
Ultimately, we need long term projects that are ‘end state’ and therefore scalable – so they are repeatable and can be scaled up. Not just little projects. We need to be able to demonstrate success. We need a framework that supports a safe rollout without making the industry unsustainable.
E-Mission Zero – an operator’s roadmap to zero – Emerald Coaches
Michael Baulch – Director
Emerald Coaches are based inland from Rockhampton, in Queensland. They chose to use hydrogen, but have since realised that there are areas like regional school bus runs that would lend themselves well to battery electric buses. But it is expensive.
Aside from the obvious advantages of zero emission tech in general, such as quiet drive, high efficiency and renewal capable, they have found other main advantages of hydrogen over electricity to be extended run time, fast fuelling and route flexibility.
A question asked by every operator about transitioning to hydrogen is whether they should make or buy?
- Fuel security and cost
- Energy cost
- Similar to diesel delivery
- Likely to be the model for most operators
- Will it be green?
- $/kg greater than on-site producing
- Capex and opportunity cost must be considered
Challenges and opportunities
The challenges are also the opportunities. The main challenge is that one size does not fit all. Whether it’s vehicles or retrofitting or infrastructure – every case is always different. It’s not like buying a diesel bus and making it work. In metropolitan areas, there can be constraints regarding the energy available in the grid. In rural areas there can be constraints around the infrastructure in place. Financing is also key. Only get finance if there is stability, contracts and clear plans.
Can augment revenue through grid support, take energy out at low price, and put back in at high price. Manufacturing possibilities. Training involvement (i.e. with universities and TAFE).
Bus industry transition
The Government has made commitments, bus industry needs to put them into action collectively. We have a willing industry. If we have the contractual regimes in place, we can get move with it. There is a huge amount of willingness to move towards renewables. All of it is technically feasible, economic feasibility is nearly there – we can see ahead now to where the costs are going.
“We can be part of the solution, but we need to take the lead on it. Let’s make a plan. It may not happen overnight (or by 2030) but let’s take the lead.”
E-Mission Zero – an operator’s roadmap to zero – Red Bus Services
Leanne Griffiths – Financial Controller
Red Bus is based on the Central Coast in NSW. A core element of their business is a commitment to the environment. Zero emission buses are a next element of their business. In 2019 they went out to market to gather knowledge, and discovered it was too early to make a commercial decision about electricity or hydrogen, so they consulted a university to get answers, and discovered:
- Depot required extensive and costly upgrades to the electricity capacity
- There are constraints with gaining electricity supply from the grid at their depot location
- Long charging times (but has improved since then)
- Insufficient maximum kilometres between charge
- No extensive costly upgrades to the electricity capacity required at the depot
- No additional electricity supply from the grid
- Hydrogen bus refuelling time is between 7-10 minutes
- Sufficient maximum kilometres between refuelling
**This was correct as of 2019, things have already changed. What they didn’t learn at the time was that hydrogen potentially can cost a lot of money in electricity when charging buses, back to back. Question is not can we charge one, but “how long will it take to charge multiple buses”?
They were chosen by NSW Govt to trial a ZEB trial program. It was to compare one electric bus and one hydrogen bus on a region of their network.
One of the complications was that there are currently no standards written, so the setup and planning processes were extensive and over long. It required a lot of communications and consultation, they consulted well before the trial (in part to allay potential fears in the community about hydrogen).
One of the things that was unexpected was the cost and magnitude of the civil works required:
- Ensuring sufficient power to run the hydrogen refuelling station
- Finding a location at the depot with power at a sufficient distance from other hazardous substances (i.e. diesel tank and the spray booth)
- Earthing the components and installing protection barriers required extensive civil works
- Installing footings to ensure the ground could cope with the pressure of the compression unit was expensive
- Finding a location that was well-ventilated with minimal traffic (vehicles and people) is difficult at an established depot where space can be limited
It took 8 months to gain DA approval to operate a hydrogen fuelling facility, with the assistance of a town planner. The DA required extensive consultation and numerous reports such as social assessment impact, bush fire report, acoustic report and environmental assessment report, to name a few. With regards to safety, because there are no standards, they had to be reliant on ad hoc engineering reports and risk assessment. It was difficult to find a balance between risk and mitigation assessments, and the financial and practical realities of doing the work.
Understanding the safety requirements for the use of hydrogen was also complicated although with Origin Energy as their partner they could rely on their expertise. Challenges faced included:
- Ensuring sufficient ventilaton
- Static control
- Lighting protection
- Factoring in movement around the fuelling unit
- Fire mitigation
They are still unsure which zero emission fuel type is the most appropriate for their business. Factors that will impact their final decision include:
- Government policy
- Price of hydrogen
- Improved battery technology
- Safety constrains around the use of hydrogen
E-Mission Zero – an operator’s roadmap to zero – Transit Systems NSW
Mark Peters – General Manager Fleet, Innovation & Business Intelligence
In their transition to ZEB, Transit Systems believe there is a place for both technologies.
Battery electric bus advantages
- Lower capital cost
- Currently better overall total cost of ownership than hydrogen
- Cost effective for small to medium scale deployments
Battery electric bus disadvantages
- Typically have range limitations
- Charging infrastructure consumes valuable depot space
- Slower refuelling time
- Typically have better range than battery
- Faster refuelling time
- Cost effective for medium to large scale deployments
- More traditional refuelling from a single facility
- Higher capital cost
- Until it hits scale, overall total cost of ownership is higher than battery
It is critical to get depot design right from the very start, so consider the end-state requirements:
- Charger selection
- Lane widths
- Manoeuvrability / ergonomics around the chargers
- Control system selection
- Prioritisation of zones
It is important to think about aligning infrastructure commissioning with the deliveries of new buses.
- Partner with reputable and competent energy and infrastructure providers/SMEs
- Invest time in getting depot design right
- Start grid upgrades and charging infrastructure early, and before bus procurement
- Where possible, futureproof
- There is a place for both electric and hydrogen bus technologies
- Collaborate as much as possible with transport agencies and the wider ZEB industry