©Bus Industry Confederation Inc. Last Updated 18 January 2016 BUSES TECHNICAL & STATISTICS\Specific Issues\

Bus Mass Limits Analysis and Report

A National Gazettal Proposal for all Bus Axle Groups

Bus Industry Confederation

January 2016

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Proposed National Mass Increases for Two and Three Axle, Articulated and Double Deck Buses Bus Industry Confederation

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Background

The BIC recently met with the NHVR in regards to bus mass limits and the main areas of discussion were:

a) The inconsistency in two axle bus mass limits across the various states, specifically that the 18 tonne two axle limit only being available in Vic, NSW and WA.

b) That the NSW 18 tonne regulation requires additional braking systems plus it specifies the method of calculation for passenger numbers. Whereas the Vic and WA 18 tonne regulations do not specify the method of calculation for passenger numbers and this is creating confusion.

c) That the mass limits for three axle buses, which currently vary from 20 to 20.5 tonne, are both inconsistent and inadequate in all states.

d) That individual axle limits for the various bus types are also inconsistent across the states.

e) That the ADR limit of 65 kg per passenger is not in keeping with the real per passenger weight and as such a bus (or coach) that is operating within its registered seated, or total, passenger capacity can still be over its legal gross mass limit. To support this, there have now been a number of in-service tests in both Vic and Qld which have shown that buses operating within their registered passenger capacity do exceed the current gross mass limits.

f) The recent bus mass review conducted by the NTC1 sighted the 2011-2012 Australian Health Survey (conducted by the Australian Bureau of Statistics) which states that the average adult male weight is 86 kg and 71 kg for an average adult female. Hence the BIC supports an average per passenger mass of 80 kg.

g) That bus tare masses are increasing due to higher passenger comfort expectations and more stringent safety and emissions regulations.

h) That the BIC’s overall position was not to increase per bus passenger capacity, but to recognise what is currently occurring and to provide a regulation framework that allows buses to operate legally both now and into the future. The BIC also supports the increased safety offered by improved braking systems and as such proposes the early implementation of such systems.

i) Finally it should also be noted that the following proposal would not affect pavement wear as the proposal is only reflecting what is actually occurring now.

A copy of the BIC position paper that was provided to the NHVR is given in Appendix B of this document.

1 NTC Mass Limits for 2-Axle Buses Discussion Paper February 2014

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Proposed National Mass Increases for Two and Three Axle, Articulated and Double Deck Buses Bus Industry Confederation

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Proposal

As a result of the meeting with the NHVR, the BIC was requested to provide a draft proposal which could be issued by the NHVR as the basis for a national Gazettal that would address the issues raised in relation to passenger weights and mass limits.

As such the BIC is proposing the following:

j) That the passenger capacity for all the following bus mass options is to be calculated using the increased per passenger mass of 80 kg and where applicable an increased per passenger luggage allowance of 18 kg per passenger (compared to the current ADR limit of 65 and 15 kg respectively).

k) That the regulations contained within ADR 58/00 still apply, but at the increased per passenger masses given in point a) above.

l) That the 6.25 persons per square metre still be used to calculate passenger standing capacity based on area.

m) It is also proposed that the increased safety standards which make up part of the NSW two axle 18 tonne Gazettal be adopted nationally in that to utilise the higher mass limits, the bus must be fitted with Electronic Braking Systems (EBS) and/or Electronic Stability Control (ESC) from 1 Jan 2016.

n) In all states the allowable gross mass for two axle complying buses to be 18 tonne, with a front axle limit of 7 tonne and a rear axle limit of 12 tonne. Hence there is a floating 1 tonne limit across the two axles.

o) In all states the allowable gross mass for three axle complying buses to be 23 tonne, with a front axle limit of 7 tonne and the rear axle combination (tonne tag and dual axle) limit of 17 tonne. Hence there is a floating 1 tonne within the front axle and rear axle group.

p) In all states the allowable gross mass for articulated complying buses to be 28 tonne, with a front axle limit of 7 tonne, a centre axle limit of 10 tonne and the rear axle limit of 12 tonne. Hence there is a floating 1 tonne across the three axles.

q) In all states the allowable gross mass for double decker twin steer and single rear axle complying buses to be 23 tonne, with a front dual axle combination of 11 tonne and the rear axle limit of 12 tonne. Due to the chassis and tyre ADR allowable limits, there would be no floating 1 tonne limit applicable to the double decker.

r) In all states the allowable gross mass for double decker complying PBS buses to be 24 tonne, with a front axle limit of 7.5 tonne and the rear axle combination (tonne tag and dual axle) limit of 16.5 tonne. Due to the chassis and tyre ADR allowable limits, there would be no floating 1 tonne limit applicable to the double decker.

s) For all bus mass options listed in e), f), g), h) and i), the chassis design gross mass, individual axle masses and the corresponding tyre capacities, as limited in the ADR SARN approvals, are not to be exceeded.

t) Appendix A includes Tables 1 to 4 that show typical passenger numbers using the 65 kg per person and current state based mass limits and the proposed 80 kg per person but with the mass increases listed in points e), f), g) and h). Table 5 shows typical passenger numbers using

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Proposed National Mass Increases for Two and Three Axle, Articulated and Double Deck Buses Bus Industry Confederation

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the 65 kg per person and current PBS based mass limits and the proposed 80 kg per person but with the mass increases listed in point i).

u) As is seen in Appendix A, there are passenger capacity increases using the proposed mass limits and per passenger weights for the two and three axle buses, but the calculations in Appendix A are based on ideal mass distributions and as noted in the tables such ideal distributions do not normally occur. Hence the achievable passenger numbers are considered to be equivalent under both scenarios.

v) Also as seen in Appendix A, for the articulated and double decker buses, the passenger numbers are nearer to equal for each scenario and the reason is that for the articulated buses the 12 tonne rear axle limit is reached prior to the total gross and for the double decker the axles are nearer to the design limits.

w) Plus although a tare increase of 350 kg has been included in the calculations, larger tare mass increases are expected in the future which would further equalise the passenger numbers achievable under each scenario.

Conclusions

The above recommendations are intended to address what is actually occurring now and is not intended nor configured to provide per bus passenger increases; moreover it is intended to ensure that buses are operated in accordance with both their legal and design limits but with real life passenger masses.

The figures provided in Tables 1 to 5 demonstrate that the proposed new mass limits, when used with a real world 80 kg per person passenger mass, are applicable to both complying bus and PBS buses.

Also in all the scenarios provided in Tables 1 to 5, the actual bus tare masses have only increased to address regulatory tare increases such as the coming Euro 6 regulations and when weight bias is fully taken into account, the number of passengers each bus type can carry under either the 65 kg or 80 kg option is basically identical.

Finally, the proposed new limits only represent what is currently occurring; hence the road network is already exposed to buses that are operating in excess of the current 65 kg per person based limits.

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Proposed National Mass Increases for Two and Three Axle, Articulated and Double Deck Buses Bus Industry Confederation

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Appendix B - BIC Summary Position on the NTC’s 2-Axle Bus Mass Limits Paper (3 Axle) as at 4 May 2015

The NTC released a paper named “Mass Limits for 2-Axle Buses Discussion paper February 2014” and the BIC provided a detailed response to this paper. An updated version of the paper has been prepared as part of meetings with the NHVR on May 7, 2015. The key issues raised by the BIC in this submission are:

Australian 2 and 3 Axle Bus Mass Limits - Australian bus mass limits for 2 axle buses needs to be increased from 16 t to 18 t and for 3 axle buses from 20 t (or 20.5 t) to 23 t as a result of an increase in the average weight of passengers overtime and also the increase in the tare weight of buses as a result of new technology, regulation and vehicle standards

UNECE 2-Axle Bus Mass Limit - The NTC paper referred to the 18 t two axle bus limit in the UNECE regulations, but the actual UNECE limit rose to 19 t for two axle buses during late 2013. This rise was due to the increasing per passenger weights and increasing bus tare mass, which is exactly the same situation in Australia as outlined above.

Uniform Mass Limits Across Australia - All bus mass regulations need to be national, uniform and consistent across all States in Australia. The BIC supports the Vic, NSW and WA government’s introduction of the 18 t two axle bus limit. The NSW regulation includes conditions related to braking systems to operate at higher mass limits. To achieve national uniformity, these conditions need to be further considered.

Uniform Bus Braking Systems for 18 Tonnes – The BIC agrees that all existing vehicles must have ABS to operate at 18 t for two axle buses, or 23 t for 3 axle buses, but requirements for higher braking standards should be introduced in accordance with the National Heavy Vehicle Braking Strategy (NHVBS). BIC is actively involved in the Phase II introduction of the NHVBS overseen by the VSS section of the Dept. of Infrastructure and Regional Development. The BIC position is that industry would agree to ESC or EBS to operate at 18 t for 2 axle buses from 1 Jan 2016 to allow all manufacturers to have such vehicles available to the marketplace. This would mean that NSW will have to move its implementation date from 1 Jan 2015, if all States could agree to this approach. BIC proposes the same requirements would apply to 3 axle bus mass increases to 23 t.

Passenger Carrying Capacity – BIC’s position is that the increase of 2 t to 18 t GVM or similar increase for 3 axle buses is not about increasing passenger carrying capacity but instead making vehicles legal as they currently operate on the road. Under the Vic and WA regulation, passenger carrying capacity can be increased. The NSW regulation has increased GVM to 18 t but retained 16 t as the GVM to determine passenger capacity. BIC supports the use of the UNECE passenger mass limit of 75 kg in conjunction with the 18,000 kg limit. This method of calculation would address the bus tare mass increase (due to Euro 5, DDA and items such as air-conditioning) whilst maintaining similar total passenger capacity numbers.

Passenger Carrying Capacity Calculations – BIC agrees that the 18 t allocation should also include a national standard to calculate passenger capacity; this can be achieved by amending ADR 58/00 such that 80 kg per passenger and 18 tonne is used in the current calculation processes. This could be introduced through SVSEG so that a national standard is achieved.

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Proposed National Mass Increases for Two and Three Axle, Articulated and Double Deck Buses Bus Industry Confederation

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Future Increases in Tare Mass – As stated, the UNECE is actually 19 and part of this was to address Euro 6. So BIC propose that a formal process be introduced to manage future increases in tare weight as a result of introduced vehicle standards (Euro 6) or other operational requirements imposed by government. This process could be via a Committee involving NHVR, SVSEG and BIC representatives where changes that effect tare mass are assessed on a factual and compliance basis.

Three Axle Buses – BIC also sees that the above issues apply equally to 3 axle buses and coaches and BIC therefore requests that the NHVR work toward having States and Territories agree to the increased mass limits for 2 and 3 axle buses on a nationally uniform basis as outlined in the BIC submission and supporting documents.

The Table below shows, in simple terms, why 3 axle buses need to have a uniform mass limit of 23 t:

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