The New Zealand Bus and Coach Association's (BCA) submission on school children standing in buses states there is no need for changes to current policies.
The BCA submission to the Industrial Relations Select Committee does not support the proposals for mandatory seating for school children on buses.
John Collyns, executive director of the BCA, says while the association fully supports road safety initiatives, it also recognises the Land Transport Safety Authority's (LTSA) mandate to promote "safety at reasonable cost".
"We take this to mean that the benefits of a particular safety initiative to the nation as a whole must outweigh the costs it may impose.
"There is certainly nothing particularly radical about this, but is an effective way to distribute scarce resources to where they will do the most good.
"As a result, we submit that the quantifiable benefits in the proposals advanced by the petitioners must outweigh the costs they will impose on bus operators, schools, the Ministry of Education, parents and other road users.
"It is our submission that they do not, and therefore should not proceed in the manner which they have been presented to the Select Committee," Collyns says.
Collyns says while the BCA prefers all passengers to be seated for comfort and, for school children, disciplinary reasons, they do not agree that seating should be mandatory.
"The reasons why we do not support the petition are:
- Banning standees will require the school bus fleet to be expanded by up to 130 vehicles, to cater for all the standing passengers who are currently carried on buses, but unable to be seated.
- The capital cost of doing so is between $8.5 million and $16.2 million, depending on how many buses are purchased second-hand. The operating costs can also be expected to increase by up to 10% - an additional $9 million annually.
- Many operators, if they have the capacity, carry ineligible students (i.e. children who are not eligible for the MoE's transport assistance) rather than let them walk or cycle along a rural highway. Even if these children stand in the bus, they are considerably safer than walking, cycling, or being driven by their parents (the Land Transport Safety Authority says that a school bus is seven times safer than the parent's car). Because they are ineligible, the MoE is unlikely to provide an additional bus and parents are notoriously reluctant to pay for one themselves. Consequently, requiring all children to be seated will expose those who would otherwise stand to a considerably greater risk of injury or death.
- The number of children on routes can fluctuate widely. Requiring operators to match seats with passenger numbers may, on some occasions, mean that children have to be left behind if numbers are unexpectedly high for some reason.
- We noted earlier that the majority of operators are small family firms who do not have the ability to match seats with children because they do not have enough vehicles to cater for significant variations in numbers. Neither is it easy to buy a vehicle to cater for what may be a temporary trough or peak in demand because good used school buses are in short supply.
- Finally, banning standees in urban school buses is neither practical nor sensible. Urban buses are specifically designed to carry standing passengers, and at peak hours it is not sensible to turn passengers away when there is space on the bus."
However, he says the BCA supports a policy change by the Ministry which would require operators to tender with vehicles which have adequate seating capacity for the number of children on the route.
"This policy change will increase the number of school buses required for the task, and would also seriously affect operators' fleet profiles.
"Most operators would have to purchase bigger vehicles to carry the same number of children. While there are a reasonable supply of mid-sized vehicles imported second-hand from Japan (that is, vehicles with about 35 seated capacity), there is a serious shortage of large vehicles with a seating capacity of 60 or more.
"Provided the builders are able to find the capacity, these vehicles would have to be built new at a cost of $180,000 each.
"School bus safety can be improved by educating parents and guardians to wait on the correct side of the road at the bus stop to collect their children off the bus, other road users who fail to observe the 20 km/hour maximum passing speed, and the children themselves to wait for the bus to move away before crossing the road," Collyns says.