Confederation of Passenger Transport Coaching Manager, Andy Warrender updates Andy Izatt on how the trade organisation is tackling some of the challenges facing the industry
Whilst the industry as a whole seems very buoyant, there’s a considerable amount of uncertainty at the moment,” explained Andy Warrender, Coaching Manager at the Confederation of Passenger Transport (CPT). “The major topic has to be Brexit in all its forms. There has been a lull in proceedings over the last four to five months. We hoped we would have answers to more questions now than we actually have.
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“The Interbus agreement will become effective immediately in the event of a no-deal Brexit. It covers the right of a UK coach to make a journey in Europe, and whilst we now know that the driver won’t require a visa, the position with work permits is less certain. The agreement does not cover the right of the driver to drive a coach so what happens about work permits and visas is important. We could end up in a situation where UK professional drivers aren’t permitted to take their coaches abroad. Operators that employ EU citizens could send them instead, but that’s clearly not where we want to be and it’s a real concern we’ve not been able to progress this.
“We’ve attended a meeting of stakeholders at the Port of Dover, which gave us some indication of the plans that are in place. It has helped build on the relationship we’ve had with Dover over the years and I think it is better prepared thanks to the industry’s input. There’s a lot of detailed work that’s gone on which will be of huge benefit once we exit the EU.
“We understand that Eurotunnel is fairly well prepared as well. It benefits from having a lot more space and road access is better. We see no sign of border control being changed from the French side and I think there would be concerns if that were even thought to be a possibility.
“Suppliers have been concerned about import duties and the complexity of the import process whether it’s for vehicles or parts. It’s not just overseas manufacturers that will be affected. UK manufacturing relies on ‘just in time’ supplies from Europe so any delay is potentially going to have a massive impact.
“We like to take an optimistic view. We think most businesses have mitigated what their position might be and made provision. Although parts availability is an issue that some coach operators are showing some concern about, there have been assurances from most of the major manufacturers that they have plans in place.
“It’s the general level of uncertainty with Brexit. If it happens at the end of October, it will come at a time when the Christmas markets are just starting to ramp up in Europe. The peak period is probably about two weeks afterwards and there’s a significant amount of traffic cross-border at that time.
“Operators plan their itineraries a long time in advance, and I think 2019 in general has been a fairly moderate year for running tours into Europe. I know of one operator that reduced its continental programme by about 30% and increased its UK offering to roughly compensate. However, it pointed out that it’s easier to fill a Europe-bound tour than a British one. It’s a little bit restricting when you already have an established UK programme.
“There are mixed reports when it comes to what is happening with the incoming tourism market. The favourable exchange rate could have been an encouragement, but the European and American markets seem fairly flat. It is people from the Far East who are making up any shortfall.
“European operators will have been in the same position as UK ones. They wouldn’t have known what the position would be when they set up their tour programmes for 2019. It’s perhaps what happens in 2020 that will prove to be the more critical barometer.”
Clean air issues
“Overall, I don’t think there has been a vast amount of difference in the number of coaches in London over the past few months, but, to be honest, I think most operators find it extremely challenging,” Andy continued. “We’ve had all sorts of issues, particularly with enforcement of the ULEZ (Ultra Low Emission Zone) – a major challenge for the industry that Transport for London (TfL) has yet to address.
“TfL tells us every vehicle is noncompliant unless it’s shown otherwise. The data TfL has received from the vehicle manufacturers should be accurate, but it doesn’t seem to be applied in a way that makes sense.
“The ULEZ is a daily issue and it is causing operators all sorts of problems. Vehicles that are compliant that are attracting PCNs (Penalty Charge Notices), compliant vehicles getting PCNs the appeals to which are then refused, and vehicles that are showing as compliant on the Checker that are still getting PCNs. We believe that the Checker uses a different database to the enforcement system. Then there are LEZ (Low Emission Zone) noncompliant vehicles that are shown as compliant for the ULEZ.
“The LEZ and ULEZ have different databases. As I said, ULEZ is based on the information that comes from manufacturers and has separate compliance and enforcement databases as well as the Checker. LEZ sits beyond all of that and is based on date of first registration. For both LEZ and ULEZ, there is also what has been added by virtue of having a certificate issued by an exhaust trap manufacturer.
“I’m sure TfL’s ULEZ database is fairly sound but its application for enforcement just isn’t working. From what we’re hearing it seems that there’s hardly an operator that comes to London that hasn’t been touched by this in some way and TfL’s response has been poor in some respects.
“One of the issues is some operators were under the impression that they didn’t have to pay until they received notification from TfL which is far from the case and actually when it gets to that stage, it’s a £500 penalty, not £100 charge.
“We have suggested to TfL is that it should issue a warning letter on the first occasion that explains the process. Only issue PCNs to operators if it happens again, but its approach is inconsistent. Some have had warning letters, others haven’t. We’re aware of one that has gone through the whole appeal process only for the adjudicator to rule that TfL can recover the full £1,000 penalty. It’s not clear from the summing up why that was and we’re currently investigating this further. Despite the industry’s efforts to try and comply, TfL has adopted a very hard line approach.
“We’re now looking towards the extension of the LEZ over a much wider area next year with some trepidation. It should be highlighted that this has nothing to do with the ULEZ extension which has no significance to coaches. That happens in 2021 and takes the ULEZ boundary out to the North and South Circular roads. From October next year, the LEZ will be tightened to Euro VI for heavy vehicles and we have real concerns that coach operators aren’t picking up on that.
“Acutely aware of the issues the ULEZ has caused, we are seriously concerned that we’re going to be facing the same with the LEZ, but on a much larger scale. The date of registration will be of no significance anymore so essentially the LEZ will have to use the ULEZ database.
“The number of vehicles affected will increase dramatically. Heathrow Airport comes into scope, for example, so there will be operators that never come into central London that will have to comply. Then there will be all the firms based in the enlarged zone.”
National implications
Said Andy: “At the moment there’s London to worry about, but by the end of next year we will also have Leeds and Birmingham, at least, and both cities have already come up against the same issues as the capital. There’s some doubt as to whose responsibility it is to compile a national database so we’re advocating that all parties get together to exchange information. Otherwise, we’re potentially going to have exactly the same problem with every new Clean Air Zone (CAZ) that’s created.
“CAZs in other parts of the country may not have arrived as quickly as was expected, but that’s down to issues largely beyond the control of the local authorities. I have no doubt that they will be trying to introduce them as quickly as they possibly can. They have air quality targets to meet.
“As there’s still only a proportion of the vehicles coming into London which are compliant, some operators are saying that customers are willing to pay the charge. Others are saying they’re not. It’s a very mixed picture, but it looks as if schools have been the hardest hit. It’s a price sensitive market and there is a general feeling that they aren’t coming as often, which is sad.
“Based on the original implementation date for the ULEZ in October 2020, TfL was predicting there would be 90%+ compliance, roughly equally split between new and retrofitted vehicles. The remainder would pay the charge. If there are now around 18,000 coaches entering the zone annually, obviously there’s nowhere near that many retrofit vehicles. There aren’t enough systems available to meet that demand so operators have no choice, but pay the charge.
“We’ve worked with the LowCVP (Low Carbon Vehicle Partnership) and Energy Saving Trust which are responsible for the Commercial Vehicle Retrofit Accreditation Scheme (CVRAS) to try and promote a streamlined approach. We advocated to DfT and the Joint Air Quality Unit, which has overall responsibility, that if money is put into easing the process by which systems are either developed or accredited, that would benefit everybody because more would be ready sooner. Nationally £1m has been allocated to help meet the cost of developing up to 16 coach specific systems including the three already available. However, the manufacturers’ efforts have been thwarted by Millbrook being shut for almost three months earlier this year for an upgrade. There are approved accreditation centres in Spain and Finland, but Millbrook is the only one in the UK.
“A sceptical person might say operators aren’t willing to pay for a retrofit so therefore the market doesn’t exist, but the fact we have sufficient interest from the manufacturers to be able to develop these systems, and that they’ve been given access to funds to help, contradicts that. However, time is limited. These systems need to be available fairly shortly because with every day that passes, there will be another raft of vehicles that drop off the list of potential beneficiaries. Either they’re getting too old or the operator has said ‘I’ve got to do something now. I can’t have a retrofit so I’m going to have to either replace the vehicle or give up the work.’
“We do see that potentially there’s a market for retrofitting older vehicles. If, for example, it’s in use day in, day out, 300 days a year, that could be a potential additional cost of £30,000 annually. Even if that vehicle is worth £15-16,000, retrofitting is still a cheaper option especially if the operator sees it having another five or six years’ life.
“I take the point there’s money available for upgrading buses. It’s something we’re plugging very hard to try and extend to coaches, but one of the biggest hurdles has been the government’s decision to devolve allocation of funds for CAZ assistance to the local authorities. With buses it’s easy. They’re local, but why would Birmingham pay money to an operator to upgrade a vehicle that spends a relatively small amount of time in the area. Some funding has been made available locally. Leeds, for example, has allocated money, but we firmly believe that there has to be a national approach to providing assistance for coaches.”
London parking
“Another big issue affecting London is parking,” Andy observed. “We’re still awaiting the promised replacement of 17 of the 27 parking bays that were removed, mostly as a result of the introduction of the Cycle Superhighways. The majority of those were on the Embankment. However, I have sympathy with the authorities because kerbside space is at a premium.
“According to City of Westminster’s own statistics for coach bay occupancy based on payments received, Park Lane, which is where some of the most used bays in the capital are, is only occupied 42% of the available time. I can walk up there anytime and very rarely are there any spaces available so that suggests operators aren’t paying. That’s something the industry has to address.
“City of Westminster’s point of view is there are 38 different uses for kerbside space. If coach bays are there, but no one uses them, why have them? It’s not economic or practical.
“Westminster’s view might seem hard, but it’s actually one of the more accommodating boroughs. They all have major problems that they’re trying to deal with. CPT engages regularly with the boroughs and have many a ‘robust’ discussion with them on certain issues, but I do have some sympathy with their position. Their agenda is laid down by those elected to represent local residents. If the industry is causing those residents a problem, its natural there will be resistance to it.
“The fact that the industry doesn’t seem to be paying its way is a real worry. We’re being asked to justify our position, but when we know those bays are being occupied and not paid for, it’s extremely difficult.
“Overnight parking in London is an even bigger issue than daytime parking because most of the on-street bays do not allow it. Since the closure of Nine Elms and the loss of Warwick Road, the two biggest overnight parks have gone. The Tower, the O2 and Bayswater Road are the only ones left and that is causing problems for both UK and oversees operators.
“Park Lane would be an ideal spot for overnight parking because nothing ever happens during the 0000hrs to 0830hrs block there is there now. The bays are remote from the nearest buildings and they’re ideally located for Kensington and Bayswater hotels as well as those closer by, but of course Westminster’s argument is that there’s no economic case for changing the regulation while occupancy is just 42% during the current operational hours.
“Possibly the most used bays in London are along the Kingsway because of their proximity to theatre land, but the big issue there is a peak time restriction. That’s not a problem in the morning, but in the afternoon there are matinee performances that coach groups attend. Drop off time can be 1300hrs, but coaches can only use the bays until 1600hrs and they can’t go back until after 1900hrs. They’re probably not picking up until 1630-1700hrs so they’re just driving around for an hour. It’s a similar problem for coaches taking people to evening performances. They arrive at 1700-1800hrs, but can’t use the bays until 1900hrs. Again they’re probably driving around in the interim.
“Westminster agreed in principal to relax the restriction a few years ago, but there is a cost and with the impending scheme to pedestrianise The Strand, it makes sense to do everything in one go.”
Coach focused
“The restructure that had gone on within CPT has given it a new impetus and focus,” said Andy. “We’re planning our annual coach conference again for December. There was an appetite last year to do something slightly differently and make it more of an event. That’s why we incorporated a ride and drive and expanded the number of suppliers that attended. We did that with EvoBus’ help and are looking to build on that for this year with another major manufacturer again sponsoring.
“The Coach Strategy we’re planning will be opened up for discussion at the conference. We want their views on the key issues which will prevent the industry moving forward over the next decade or so. We’ve already started talking to our members, but that discussion may uncover some areas we’ve not looked at already. The event will be open to non-members for the first time, making it more of a national coach industry event.
“Operational issues are really what coach operators are predominantly interested in. They’re all concerned about what’s happening with the CAZs and Brexit and what it means for their particular businesses. It doesn’t matter if they send vehicles abroad or not. It’s going to have some impact.
“Then there are the other day-to-day issues they have to deal with. In some areas it’s not being able to get an MOT test. In others, it’s problems setting down and picking up at schools because councils have introduced yellow boxes or zig zags. The CPT regional managers have an important role in dealing with local authorities. It’s extremely valuable having people like them on the ground who know the locality. The operational team back that up with more specialist in-depth knowledge, but there’s no substitute for local knowledge so keeping those ‘feet on the ground’ is key.
“We’re in an era now where councils don’t have a lot of resources and are perhaps no where near as engaging as they used to be. It’s disappointing, but a sign of the times. Nowhere is that more apparent than in London, but while the capital can sometime appear to dominate, that can be misleading. It’s not a place that the entire industry is focused on. Many don’t visit it so it’s important for the CPT to provide a balance, which I think it does fairly well.”
Challenges ahead
“Despite all the turmoil, the industry still seems positive at the moment and continues to be remarkably resilient,” said Andy. “However, there’s a lot on the horizon that it will have to contend with.
“Alternative fuels are one area. Will zero emissions coaches be a practical proposition? We know they will be for certain applications, but it’s how wide that sphere of operation is going to be. There’s Yutong with the first electrics and I admire Irizar for the way it has promoted hybrid. There’s a thought that gas will be a more viable solution, but there’s scepticism amongst some as to how practical it will be. It’s all very much in the melting pot and vehicle manufacturers are being very cautious. Diesel will have a future, but I think we all know, as a proportion, it will make up less of the vehicle parc in the future. The trade shows over the next couple of years are going to be particularly insightful as to how the industry is going to approach it all.
“Staffing continues to be a major concern. Coach operators say they never have enough drivers, but there isn’t a structure in place that allows the people they employ to progress. There’s no incentive that encourages them to do well and the industry often loses the kind of staff that it should be looking towards to take it forward. What the industry should be thinking about is the cost of a £300,000 vehicle standing idle because there’s no one available to drive it.
“I’m not so sure that the cost of entry is the problem. I talked to an operator recently that has set up internally to train drivers. It costs roughly £1,200 to £1,700 depending on how good the candidate is and it can pick who it wants. A lot of recruits are coming from the retail sector where, by comparison, being a coach driver is quite well paid and generally a more attractive job. Even if it doesn’t work out and that operator gets three months out of a new recruit, against the possibility of a £300,000 asset standing idle for even just a small proportion of that time, it has recouped its money.
“I don’t think the costs of entry pro rata in relation to the earnings that can be achieved are really any different to a lot of other industries. Any industry needs to be able to train the staff it needs, but there just isn’t an appetite to do that in coaching, particularly amongst smaller operators. It’s an area that the industry as a whole is showing a reluctance to tackle.
“Possibly the biggest issue currently is PSVAR (Passenger Service Vehicle Accessibility Regulations). There’s a perception that it’s something new, but the legislation actually came into force as long ago as 2001. For coaches the requirement for wheelchair accessibility was from 2005 when they’re used on scheduled services but the shift towards fares being charged on an ever increasing number of school routes by cash strapped local authorities, has meant a much higher proportion of these services have now been caught within scope of the regulations. This is something which many coach operators would never have anticipated.
“To the industry’s credit, I think it’s more sophisticated and safer than it has ever been. Even though they have no powers to enforce it, it’s good that the Traffic Commissioners are keen to encourage continuous professional development. With so much change, that can only be to everyone’s benefit.”
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