Where does the bus industry currently sit with zero emissions

A rapid transition to Zero Emissions Buses (ZEBs) is occurring across Australia. This transition is outpacing the governments’ ability to develop an appropriate policy and regulatory framework which will ensure the safe design, configuration, operation and maintenance of these heavy vehicles whose primary function is to move people. To fill this void in the short to medium term it is proposed that industry develop codes of practice, advisories and guidelines. Government must fund the development of these resources as a matter of urgency before there are any critical incidences related to these new technologies.

We welcome well considered feedback from industry stakeholders by using this online form.

The rapid transition to zero emission bus fleets

The bus and coach industry are early adopters of new technologies as evidenced by the uptake of Euro VI emission standards. Over 20% of new bus deliveries in Australia in 2018-19 were of Euro VI standard even though this emission standard is not expected to be mandated until 2027.

Bus operators, particularly those contracted by governments to deliver public transport services, are also at the forefront of the transition to zero emission vehicles. Across the nation the state and territory governments are announcing the introduction of Zero Emissions Buses (ZEBs) into the public transport fleets. The level of ambition varies somewhat from the announcement of trials in some jurisdictions to the electrification of the entire bus fleet of 8000 by 2030 in NSW.

The transition to zero emission technology has also been seen in the long-distance tour and charter sector. For example, Fortescue Metals Group will see 10 full-sized hydrogen coaches replace diesel coaches at the Christmas Creek mine from 2021. While these hydrogen fuel cell buses will primarily operate on private roads Queensland private passenger transport operator Emerald Coaches will replace its entire 120-strong fleet with hydrogen fuel cell electric vehicles by 2040, at an estimated cost of $100 million. As the largest provider of school bus services in the Central Highlands in Queensland the company will complete more than one million passenger trips per annum on hydrogen powered buses starting at the end of 2022. The NSW Governments Hydrogen Strategy sets a target of 20% hydrogen vehicles in the Government heavy vehicle fleet by 2030.

With zero emission buses and coaches now on roads in rural, regional, and metropolitan Australia the Bus Industry Confederation is concerned about the lack of standards, regulation, guidance and policies related to the manufacturing, operation, refueling, servicing and emergency management of these buses.

For example, there are currently no formal qualifications for mechanics who will be servicing ZEBs despite these vehicles having high voltage power systems and in the case of hydrogen, extremely high pressure storage tanks and distribution systems. Similarly, there is no training for first responders in an accident or harmonisation in terms of warning signs.

No Australian Design Rules exist that specifically address the unique characteristics of ZEBs this is dispute there being a range of overseas standards and codes that could be implemented into the Australian market. We understand that they are currently not listed on the Australian Design Rule Development Program which is currently focused on rules associated with the safe vehicle section of the National Road Safety Strategy 2021-30.

Australia runs the very real risk of having unsafe zero emissions heavy vehicles operating on our roads and sitting in depots located in suburban areas. Further we run the risk of a repeat of the rail gauge fiasco whereby each of the colonies of Australia adopted their own gauges in the 19th century making border crossings all but impossible.  In this case charging infrastructure may be different in each jurisdiction and long-distance coaches and trucks may face recharging issues.

An interim solution to a lack of a policy and regulatory framework

The speed of adoption of ZEB technology has been significantly faster than government’s ability to develop an appropriate policy and regulatory framework to ensure the safe design, configuration, operation, maintenance of these heavy vehicles whose primary function is to move people.

At this stage a regulatory response would be too slow to provide the guidance needed to industry particularly as the current ADR development program focusses on the safe vehicle section of the National Road Safety Strategy. The policy and regulatory framework also needs to be broader than design rules covering a broad range of issues including training and skills development, infrastructure (charging and other), safety and emergency management for example. 

An interim solution would be the development of industry codes of practices and advisories. We note that National Heavy Vehicle Regulatory supports the development, promotion, and adoption of codes of practice targeting sector specific risks.

National advisories related to ZEBs would assist manufacturers and suppliers, operators, and infrastructure providers, first responders and all levels of government. Industry developed and supported national advisories and guidelines such as the BIC fire mitigation advisory and the BIC Bus Fire Evacuation protocol have been used effectively in the past to deal with emerging issues at a national level. The advisories have been prepared by the BIC and promulgated by the Australian Government to the states and local governments and act as a precursor to regulation in many instances. These advisories are also widely adopted by the heavy vehicle freight sector.

The BIC is in the position to rapidly commence work on developing ZEB guidelines and advisories. We have already established a ZEB committee involving representatives from bus operators and manufacturers, charging infrastructure and energy source experts, academics and education providers. Supporting the committee is an industry reference group that helps the committee identify issues and priorities and will help to ensure ownership and adoption of the guidelines and advisories.

Heavy freight vehicles peak industry bodies have indicated that they are seeking bus industry leadership in this area given our status as early adopters.