With London’s ULEZ just around the corner, Peter Jackson spoke to CPT Coaching Manager Andy Warrender to learn more about the impact it could have on the coach industry this year
London’s Ultra-Low Emission Zone (ULEZ) has proved to be the subject of much debate within the coach industry since it was first consulted on in 2014. Now though, its introduction is only days away, so it seemed like the ideal time to catch up with Confederation of Passenger Transport (CPT) Coaching Manager Andy Warrender. [wlm_nonmember][…]
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Joining the CPT that same year, Andy has been involved with the zone’s introduction for the last five years, and was keen to stress to operators the importance of planning ahead: “There’s a crucial element to this; people are ‘sleepwalking’ into this thinking they’ve got compliant vehicles and they don’t have to worry about it,” he said.
“On the Transport for London (TfL) website there’s a vehicle checker, and we’re reminding operators that – even if their vehicles are compliant – they need to use it to make sure they’re on the TfL database.”
The reason for this is simple: “There is no definitive database of Euro VI vehicles,” Andy explained. “Nobody knows which vehicles are Euro VI and which aren’t other than the people that built them (and the people that bought them).
“The enforcement database that’s behind the ULEZ had to be populated with all of those vehicles, and TfL has done that – with our help – through engagement with each of the vehicle manufacturers individually. Manufacturers have all been asked to supply details of vehicles’ engines and Euro standards. In fairness to them, they seem to have taken to it quite well. For some of them, it’s been a massive exercise.
“The database as it stands now is as good as it’s going to get – at least without further intervention from the users themselves. So, everybody that has a Euro VI vehicle needs to check on the TfL website to make sure that it is actually recognised on the database.”
Next steps
Fortunately for operators, checking whether vehicles are registered on the database is a straightforward process. Available at
bit.ly/ulezchecker, TfL’s vehicle checker facility allows users to input a registration number to get an instant answer as to whether the vehicle will be subject to ULEZ charges.
With the registration number confirmed, the site will then deliver one of three responses: “Either it’s recognised as compliant, it’s recognised as not compliant or it’s not recognised at all,” said Andy.
“If it is a compliant Euro VI vehicle but isn’t being recognised as such, you need to create a copy of the vehicle’s certificate of conformity (or a letter from the manufacturer confirming the vehicle meets ULEZ standards) and the V5. Because the certificate of conformity won’t have the registration number on it, TfL needs to be able to link the V5 (which has the registration number and the VIN) with the certificate of conformity (which will have the VIN and the emissions status of the vehicle).
“Once you’ve either scanned or photographed those, there’s a facility on the TfL website to make an enquiry (available at bit.ly/ulezenquiry). State what the enquiry is, and there’s a supplementary evidence section where you can upload the images.”
Checking vehicles now could save considerable time and hassle in the long run, warned Andy: “If a compliant vehicle enters the ULEZ but isn’t on the database, an operator then has to go through the appeals process – which means they’ll have to prove the vehicle’s compliance (using the enquiry page on the website mentioned above) anyway. So, they might as well do it ahead of time to avoid getting charged.”
Andy was keen to pay tribute to TfL’s Principal Analyst Adam Moody, who has been responsible for compiling the database: “Adam has worked extremely hard. He was presented with a real poisoned chalice last summer when he began the process of compiling the database, and we had a discussion with him to determine the best approach for it.
“We were never going to get the database 100% – I think we all appreciated that – but now the onus has to be on the user to make sure their vehicle is on there.”
Those wishing to send non-compliant vehicles into the ULEZ would be wise to set up automatic payment accounts for ULEZ charges, Andy advised: “If a coach is dropping off passengers on Park Lane, for example, but a customer asks to be dropped off somewhere inside the ULEZ, the operator may never know that the vehicle’s been into the zone and a week later they’ll receive a penalty charge.
“To that end, it really is a huge benefit if all of their vehicles that are ever likely to come into London are on that account. If they never come in, they won’t get charged, but it removes that risk of operators getting a penalty charge.”
Is the industry ready?
With such an abrupt transition from Euro V to VI, I asked Andy whether the industry was truly prepared for the introduction of the ULEZ. “I would say the industry is as prepared as it possibly could be for the ULEZ – there’s been huge investment over the last four or five years,” he replied.
“The early days of Euro VI were clouded by the continued availability of Euro V, and there was also no indication at that point that Euro VI was going to become mandatory in certain cities within such a short period. The first Euro VI vehicles were built towards the end of 2013, but there were still Euro V coaches being sold into 2016 and even 2017.
“TfL predicted at least 90% compliance for the ULEZ when it was originally consulted on,” Andy stated. “At that point, the zone was due to come into force in October 2020. When it came forward, they never revised that compliance forecast – they just left it as it was.” To put the compliance shortfall into perspective, Andy explained that around 21,000 coaches visit London every year – but as of today there are around 5- 6,000 Euro VI coaches registered in the UK full stop.
“In broad terms, around 50% of 2014 vehicles would have been Euro V, and by 2016 around 20-30% would still have been Euro V; there are still a lot of very modern, recent vehicles out there that are Euro V,” Andy pointed out.
Those vehicles could potentially have many more years of life in them – particularly if retrofitted to be Euro VI-compliant. However, as Andy explained, coach retrofits remain in short supply: “The retrofit market which was promised and expected hasn’t yet materialised for coaches. The bus market is there, but coaches are still very much on the back foot; retrofit manufacturers are playing catch up now with this. If we’d been in the position that we are now 12 months ago, it probably wouldn’t have even been satisfactory then, simply because retrofit providers are quoting delivery times for vehicles to be fitted of September/October – quite an extensive lead time.
“It was originally expected that the compliant vehicles would be made up of 50% new and 50% retrofit, but those retrofit vehicles as far as coaches are concerned just aren’t there,” Andy continued. “Currently, there are only four or five coaches on the ULEZ database that are retrofits – all of them Eminox-converted Volvo B9Rs.”
The situation could still change though; CPT is aware of a number of coach retrofits which are currently in development: “The Baumot system for the Scania K360 is there or thereabouts – it’s been through Millbrook and the application is with the Energy Saving Trust – so that should be certified any day now. That said, production of that system, like any retrofit, is dependent on it being certified, so it’s only just been put into production. It will likely be available for installation in the summer.
“I understand that Eminox has more coach retrofits in the pipeline. We’ve had some discussions with them because they’re really looking for a steer on what the interest is for certain vehicles.
“I don’t think it’s unreasonable to expect a retrofit for the Volvo B11R, another B9R system to rival Eminox’s, and a system for both the nine and 11-litre PACCAR engines is in the pipeline as is one for the Mercedes-Benz Tourismo.
“If operators are interested in retrofitting a vehicle, we recommend they get in touch with system manufacturers who can advise accordingly which vehicles they’re looking at producing retrofits for.”
Up against it
Of course, there are numerous reasons for the current absence of coach retrofits. First of all, the sheer number of coach body, engine and chassis combinations presents retrofit manufacturers with a huge challenge. Andy explained: “We conducted a survey of CPT members around this time last year to look at the number of possible combinations of Euro V vehicles which could potentially be candidates for a retrofit. Before we started, we did our own count of the number of variants of just Euro V vehicles which we knew to have been sold. We got to 225 before we stopped counting!
“I do feel a bit sorry for the retrofit manufacturers because they really are stabbing in the dark with this. Trying to draw any conclusions about potential demand for systems out of the survey we conducted was very difficult, purely because the responses identified a huge variety of vehicles and not enough volume to justify pursuing it further. Also, at that stage, operators gave no real indication as to which way they were going to go – were they going to replace vehicles, retrofit or just pay the charge? We didn’t get enough detail to draw meaningful conclusions.
“The interest in the coach industry from retrofit manufacturers was there from the start, but the enthusiasm to pursue it wasn’t particularly. Firstly because there was no funding (whereas there was for bus), and secondly because of the huge variety of coaches out there compared to buses and how strict the accreditation scheme was initially. If the scheme had stayed as it was, it would have required over 200 accreditations – and at £100,000 a time, it was clearly a non-starter.
“We worked extremely hard engaging with the Energy Saving Trust and the LowCVP, as guardians of the retrofit accreditation scheme, to come up with something that was pragmatic. You can have a cast iron accreditation scheme that absolutely guarantees a system will work, but it ends up increasing the cost which then reduces the level of interest operators might have in the system – which doesn’t do any good for air quality.
“For that reason, we lobbied for a pragmatic approach to certification. If the engine that’s certified is the dirtiest version of that engine and it still meets Euro VI with the retrofit installed, then logically it should work on other versions of the engine. In fairness to the Energy Saving Trust, they were pretty receptive to it because their main aim was to try and improve air quality. If there are 100 systems out there and they’re having some impact on air quality, then it’s a move in the right direction as far as they’re concerned. But if the accreditation process is so rigid that fewer systems are available, it defeats the object.
“The fact that the accreditation has been relaxed now should bring more retrofit systems on-stream. I’m not saying the cost is going to reduce dramatically, but hopefully with some economies of scale it should come down to something a little bit more manageable. But it’s likely to still be circa £15,000.
“On a vehicle that’s 15 years old, it’s questionable whether it’s worth it – although for operators who come into London virtually every day, even older vehicles may be a viable candidate for a retrofit. If the options are spending over £100,000 replacing the vehicle or maintaining it for three or four years at a cost of £15,000, the payback is a lot more attractive.”
Regardless of the reasons behind it, the lack of retrofit options has had a considerable impact on the value of Euro V coaches, said Andy: “Five years ago, there was a general rule of thumb that a Euro V vehicle was worth about £20,000 less than an equivalent Euro VI of the same age, model, mileage and so on. This was roughly the price difference between the vehicles when they were new, and also circa what was being quoted at the time for a retrofit.
“Based on that, some operators decided to save a bit of money when buying the vehicle thinking that they would be able to upgrade it in future if they needed to and not really lose out.
“Unfortunately, without the availability of retrofits that price difference is now huge. For equivalent vehicles, the price difference is now around £50-60,000 – maybe more. It’s largely driven by supply and demand, because there are an awful lot of Euro V vehicles out there which currently nobody wants.”
Andy mentioned that the CPT had asked for TfL to consider allowing Euro V vehicles into the ULEZ which had a retrofit system ordered, due to the extensive waiting list to get systems fitted: “We proposed that if a vehicle had an accredited retrofit system ordered, but the manufacturer was unable to supply it for a few months, then that vehicle could continue to enter the ULEZ free of charge until the system was fitted.
“TfL was kind of receptive to that idea, and asked what we thought a reasonable timeframe was for vehicles to be allowed to continue entering the zone. We suggested six months from April at the time, but as of right now we’ve not heard whether that’s going to be forthcoming.”
More positive news may be on the horizon, suggested Andy, as more funding becomes available to retrofit manufacturers: “The revenue from the ULEZ is going to be a lot higher than was originally expected – as TfL’s compliance forecast won’t be met – and it of course has to be spent on air quality projects. £1.1m has been allocated as part of the national air quality funding to retrofit system manufacturers, which is good news.
“All of the public money that’s gone towards air quality so far has been devolved to individual regions to spend. For a coach, this is hopeless – coaches just don’t apply to the criteria that are considered when this funding is handed out in the local area. For instance, if Nottingham was given £1m to spend on air quality, it wouldn’t choose to retrofit a coach that spends most of its time in Austria or Birmingham.
“CPT argued that funding should be allocated at national level to be of any benefit to coach, and it’s good to see that our suggested approach has been adopted and funding is to be put to manufacturers to develop and accredit retrofits. I believe there are about 17 systems which would be applicable to coach from three manufacturers which are included in that. The funding probably works out at about 20-25% of the cost of developing and accrediting a retrofit – not massive, but it might just edge some of the more niche systems towards viability.”
The way forward
Clearly, the Mayor of London has embraced the concept of low and ultra-low emission zones, but will the rest of the UK follow suit? I asked Andy whether he thought low-emission zones (LEZs) would be the future: “I would be amazed if they aren’t. They’re not the only option – we’ve already seen Nottingham and Southampton take other routes, which is encouraging. But, to be perfectly honest, it would be extremely naïve to expect that to be the norm.
“We’ve got localised air quality issues in hundreds of places. A couple of years ago, there was never question of an air quality issue in Peterborough, for example, and now there is.
“It’s almost attracting a ‘me too’ approach – ‘if they’re having a clean air zone (CAZ), I want one too!’ I’m convinced there’s an element of that in it. It’s a political thing rather than a purely practical thing. Nobody knows where it’ll end up, but CAZs are definitely coming to somewhere near you.”
With low-emissions zones looking set to become the norm across the UK, Andy believes there will be a lot to learn from ULEZ pioneers London: “I think an awful lot will be learned from London. London’s led the way with clean air – LEZ has been with us for about 15 years now – and they’ve always been the trailblazer. But London has had to plough its own furrow with some of this, like the Euro VI vehicle database we talked about earlier.
“They’ve put a lot of hard work into collecting that data, and whether they’ll want to share it with the likes of Birmingham, Leeds and so on remains to be seen. We’ve had some very interesting discussions; the issue of GDPR keeps coming up and nobody has actually justified it.”
Lessons can also be learnt from the industry’s past, suggested Andy, referencing the changes which came about as a result of accessibility regulations in the ‘90s. “There’s a parallel here with the introduction of low-floor buses,” he said. “If you go back a couple of decades, a lot of local bus services in rural areas were operated by coaches; the vehicle could do its normal work during the day, a school run in the morning and afternoon, a bingo job in the evening and was available for private hire at the weekend. So back then, a coach could have had quite a broad revenue stream. But when accessibility regulations came in, half of its revenue was all of a sudden transferred to another vehicle (a low-floor bus), so you needed two vehicles to generate the same revenue one coach could have done previously.
“One thing which happened as a result was that a lot of coach operators ended up becoming purely bus operators. Two that spring to mind are Delaine of Bourne, which used to run coaches but no longer does, and DRM Buses of Herefordshire. I’m sure if you ask them, it’s purely down to that; their core businesses were in bus operation, which they could use coaches on and supplement their revenue, helping towards the cost of running the bus services. With that ability to use coaches as dual purpose vehicles on bus services gone, they then had to concentrate on one area. Nobody really wants to go from Peterborough to Hunstanton on a low-floor bus, so the core operation became their priority and the coach operation simply declined.
“The ULEZ is going to do similar things to the industry I think, because whilst a coach might be doing a school contract in the morning, on Saturday it might have to go to London. Paying the non-compliance charge may make that London job unviable and with a core revenue from school work, upgrading to a new vehicle simply isn’t an option.
“In truth, things like the ULEZ are going to be a huge ‘filter’ for the industry, because the non-compliant – and those who aren’t really interested in being compliant – will go out and do things for the lowest possible cost in a world where costs are rising. Ultimately, it will be those operators that fail.”
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