motorcoach solutions - for the future of surface transportation

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MotorcoAchsolUtions

for thE futurE of SurfacE tranSportation

Published by the American Bus Association. Printed By McArdle. Printed and bound in the United States of America. No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying, recording, or

any information storage or retrieval system now known or to be invented, without permission in writing from the American Bus Association, 111 K St. NE, 9th Fl., Washington, DC 20002, except by a reviewer who wishes to quote brief passages in connection with

a review for inclusion in a magazine, newspaper, electronic publication or broadcast.

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this handbook serves to provide a comprehensive picture of the motorcoach industry and the American Bus Association’s (ABA) role in promoting a wide range of legislative and policy issues at all levels of government.

ABA represents approximately 1,000 motorcoach and tour companies in the united states and Canada. Its members operate charter, tour, regular route, airport express, special opera-tions, and contract services (commuter, school, transit). Another 2,800 member organizations represent the travel and tourism industry and suppliers of bus products and services who work in partnership with the north American motorcoach industry.

indUstry seGMents Motorcoach Operators | operators own motorcoaches and provide services such as charters, tours, sightseeing, scheduled service, school bus service, special operations, and/or local receptive operations.

Tour Operators | organize tours without owning equipment and contracts for coach and other transportation, for hotels, at-tractions, and other travel suppliers to offer a package. the tours are primarily to locations away from the company’s hometown.

Travel Industry | tourism-related companies and organizations include travel/tourism/destination marketing organizations, accommodations, attractions, food service organizations, and tourism service professionals, such as receptive operators who specialize in tour planning for a local area.

Associates | Manufacturers and suppliers of bus products and services.

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Protecting cost-effective mobility is commonsense transportation policy

Independently owned and operated motorcoach companies provide a variety of services including scheduled, charter, sightseeing, and commuter transpor-tation. Private bus operations fill in mobility gaps across the country, provid-ing cost-effective travel options for the American public, whether traveling for work, vacation, connecting to other transportation options or moving people from rural communities to urban centers.

Motorcoaches accounted for 762 million passenger trips in 2008, moving more people than the domestic air carriers do in some years, and more than 30 times what Amtrak does annually.

For millions of rural Americans, motorcoaches are the only available mode of public intercity transportation service, going where air and rail do not. There are five times as many motorcoach terminals nationwide as there are airports, and six times as many bus terminals as there are intercity rail terminals.

Travel by motorcoach yields priceless ecological dividends, removing cars from the road, reducing energy consumption, and slashing carbon dioxide emissions.

On average the private motorcoach fleet provides 206 passenger miles per gallon (MPG), the highest among all modes of transportation.

Commuter rail averages 92 passenger MPG, transit buses achieve 31 passenger MPG.

Domestic air carriers realize 44 passenger MPG.

Personal automobiles average 27 passenger MPG, and hybrid cars 46 passenger MPG.

Each year in the United States, motorcoaches account for 44.2 million gallons of fuel saved, 63 million hours of time saved.

Motorcoaches aren’t just a way to go green—they also help drive our economy by infusing tourism dollars everywhere they go, creating jobs and boosting tax revenues at destinations and attractions in every state.

Motorcoach traveler and tourist demand creates jobs for 1 million Ameri-cans, generates $40 billion in wages, and accounts for $112 billion in total economic impact annually.

At a time when members of Congress are looking for cost-effective transpor-tation solutions, nothing compares to the motorcoach for affordable, accessi-ble, hassle-free travel that connects Americans like no other mobility option.

Motorcoaches Put America in Motion

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Provide private motorcoach industry diesel fuel tax parity with passenger rail and publicly funded mass transportation.

Provide tax credits and granting programs for new motorcoach purchases to support rural trans-portation, job creation, and envi-ronmental stewardship.

Increase funding for ADA com-pliance to $47 million annually. This money will cover the actual cost of compliance, and help motor-coach operators provide service to all Americans.

Increase transportation access for rural Americans by enforcing consultation requirements and supporting the FTA Private Match Program.

Establish an Essential Bus Service program to help fill in the gaps in America’s rail and air trans-portation network.

Protect the millions of Americans who travel on private motorcoaches every year by enacting long-term authorizing legislation providing “Over-the-Road Bus Security Assistance.”

In order to continue serving the traveling public and incorpo-rate federally mandated safety and environmental standards the private motorcoach industry needs to maintain the current axle weight exemption.

Give the Federal Motor Carrier Safety Administration (FMCSA) additional enforcement tools to keep our roads safe.

Incorporate motorcoach services in federal and state transportation planning as part of an integrated mass transportation solution.

Motorcoach Industry Key Legislative Priorities

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Contents ABA Position Papers 7 economic Development

8 The Motorcoach Industry Position on Fuel Taxes 9 Motorcoach Fleet Reinvestment and Revitalization 10 Motorcoach Inclusion in Intercity Passenger Rail Expansion 11 Charter Rule Enforcement 12 Transportation in the National Parks

13 network of services 14 The Expansion, Conversion, and Creation of HOV & HOT Lanes 15 Tolls and Congestion Pricing 16 ADA: Closing the Mobility Gap for Passengers with Disabilities 17 Dedicated Funding for Intermodal Transportation Facilities 18 Increased Funding for Meeting Rural Transportation Needs 19 Motorcoach Solutions to Airport Congestion 20 The Motorcoach Industry Position Essential Bus Service

21 Motorcoach operations safety & security 22 Motorcoach Occupant Crash Protection 23 Bus Accident Research 23 Motorcoach Security 24 Motorcoach Axle Weight Regulations 25 Driver Qualification Information 26 Electronic On-Board Recorders (EOBRs) 27 Hours of Service Changes for Intercity Motorcoach Drivers 28 Safe and Fair Implementation of NAFTA 30 The Motorcoach Industry Position on Information

Sharing & Analysis Centers (ISAC) 31 environmental travel Choice 32 The Motorcoach Industry Position on Idling Regulations 33 Biodiesel Fuel Additives vs. New Fuels and Engines

Research & Reference 37 Motorcoach Census 40 National Economic Impact 42 Federal Subsidies for Passenger Transportation, 1960-2009 48 Updated Comparison of Energy Use & CO2 Emissions from

Different Transportation Modes35

Economic DevelopmentABA Position Papers

Economic DEvElopmEnt – ABA Position PAPers 7

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8 ABA Position PAPers – Economic DEvElopmEnt

eConoMIC DeVeLoPMent

Motorcoach services cre-ate economic stimulus in communities both large and small by providing jobs, bringing tourism dol-

lars, and creating transportation options for the commuting public. Motorcoach tourism creates opportunities for economic growth across a broad range of industries from din-ing, shopping, and hotels to attractions and shows. The industry is part of the engine that drives communities by creating employment, increasing income and sales tax revenue, and by offering mass transportation to important destinations such as hospitals, colleges, air-ports, and government centers at little or no cost to the taxpayers. Burdening our services

through increased taxes or fees reduces the benefits we bring to communities and can impact businesses that depend on tourism, travel, or a mobile workforce.

The Motorcoach Industry Position on Fuel Taxes

Issue | The Highway Trust Fund (HTF) spending outpaced the level of fuel tax rev-enues that support the fund in 2009. Changes in fuel tax collection sources and procedures, which could have a significant impact on the motorcoach industry, are under serious con-sideration in response to this deficit situation.

Background | Congress is simultaneously facing large budget deficits and public ex-pectations that investment in transportation infrastructure will continue to grow. The HTF revenues come largely from the fuel tax but also from taxes on trucks, trailers, heavy vehicles, and tires. In the future, the country cannot depend on fossil-based fuel taxes to fund its surface transportation system, in part because increasing fuel efficiency standards and alternative fuels make the already inadequate gas tax a declining revenue source.

Much effort was focused in SAFETEA-LU on addressing the funding shortage through tackling fuel tax evasion; reconciling pay-ments that needed to flow into the HTF for dedicated transportation spending versus the general fund; and focusing on unneces-sary exemptions. But because those changes are not sufficient to address the problem in

the future, more options are under consid-eration. In the last several years, there have been several test projects to use road user fees to back bonding on road improvements and manage access to the road capacity, particularly at peak hours. Other options include: eliminating fuel tax exemptions taken at the pump in favor of fuel tax exemp-tions being paid through revenues (presum-ably reducing current “abuses”); shifting costs to states to help fund the infrastructure; indexing the fuel tax to the Consumer Price Index, retroactively to the last federal fuel tax increase; creative ways to increase the HTF contributions of alternatively fueled vehicles; and a vehicle miles tax (VMT) for all highway

economic impact of Motorcoach-Based travel in the United states

Direct Supplier Induced TOTAL

Jobs (FTE) 608,200 147,400 301,200 1,056,800

WagEs $19,010,656,500 $7,808,208,800 $13,768,603,500 $40,587,468,800

Economic imPacT $42,281,666,900 $24,527,578,500 $45,858,287,600 $112,667,533,000

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users regardless of the vehicles they operate (under such a system the gas tax would be substituted with a mileage-based fee).

Currently, motorcoaches pay 7.3 cents in taxes on diesel fuel as a result of an industry-wide 17 cent exemption from the current 24.3 cent diesel fuel tax. The benefits private operators bring to the system are the same contributions made by transit operators receiving a total fuel tax exemption: taking cars off the road and the resulting conges-tion mitigation, rural access, commuter efficiencies, environmental and pavement-wear benefits. Motorcoaches are the most fuel-efficient commercial passenger trans-portation service.

ABA Position | ABA seeks to gain parity with rail and publicly funded mass transpor-tation in the application of diesel fuel taxes based on the following arguments: 1) buses take cars off the road helping to mitigate congestion and minimize pavement wear; 2) use of motorcoaches, the most fuel-efficient passenger mode, provides a positive envi-ronmental impact; and 3) heavily subsidized transit agencies and Amtrak are exempt from fuel taxes, private operators providing the same benefits should receive the same ben-efits. If the existing subsidy gap is allowed to grow an additional burden will be placed on the privately operated public transportation network causing these operators to cancel marginal or rural service and increasing the need for public resources. This additional burden will reduce transportation alterna-tives and increase the demand on services that cost taxpayers more.

Motorcoach Fleet Reinvestment and Revitalization

Issue | Due to federal mandates on new technology and the reduction in the overall fleet size the cost of the average motorcoach has increased over the last 10 years by more than 40 percent. The unprecedented rise in vehicle cost has forced companies out of

business and driven the average age of the motorcoaches operating today up by nearly 60 percent. As federal regulators prepare another round of safety and environmental mandates they must also consider ways to help the motorcoach industry cope with the costs of more regulation.

Background | Over the last 10 years feder-al mandates that include four Environmental Protection Agency (EPA) engine mandates and American’s with Disabilities Act (ADA) accessibility requirements have increased the average purchase price of a new motor-coach from approximately $340,000 in the year 2000 to $480,000 in 2009.

While similar ADA requirements have been imposed on publicly funded transit sys-tems they have enjoyed granting and funding programs that cover 100 percent of the com-pliance costs associated with the purchase of equipment and training. In regards to EPA engine mandates the motorcoach industry cannot take advantage of the economies of scale like other industries due to the rela-tively low production volume. Motorcoach manufacturers produced approximately 1,600 units in 2009 and have not exceeded 3,200 units in the last 10 years. Despite the costs the industry has embraced new engine standards and increased accessibility. Travel by motorcoach is now the most the environ-mentally efficient means of motorized travel on the road today.1 The industry has also worked with our colleagues in the disability rights community to create best practices so that our services are open to all people.

However these advances have come at con-siderable cost borne almost entirely by bus operators. As costs rise, margins are forced lower which prevents capitalization of new vehicles. If the motorcoach fleet continues to age due to fleet capitalization expenses, we will see even greater attrition of small busi-ness, the loss of jobs, local tourism dollars, and increased congestion across the country.

ABA Position | The motorcoach industry needs capital assistance through a combi-

1) Getting There Greener” Union of Concerned Scientists (2008)


nation of tax credits, granting programs, low-interest capital loans, and private investment. Pathways to achieve this could be through the implementation of invest-ment tax credits, federal granting programs, as an eligible project under TIFIA or a newly created infrastructure bank. Ultimately, such investment could have multiple economic benefits including: 1) encouraging capital investment in the nation’s motorcoach industry (the most energy-efficient and environmentally beneficial form of motor-ized transportation) while working to curb the economic downturn in the motorcoach industry; 2) taking more cars off the road, and in doing so reducing pollution and other negative environmental impacts; 3) promoting the expansion, improvement and affordability of bus service to both rural and underserved areas of the United States; 4) assisting motorcoach companies in bringing down the average age of their fleet; 5) promoting the creation of new motor-coach companies to serve the traveling public; 6) supporting job creation and economic stimulus; and 7) opening up capital markets with new equipment sales, new and old motorcoach sales, and expansion of service routes.

Motorcoach Inclusion in Intercity Passenger Rail Expansion

Issue | As presented, the U.S. budget blue print for the next 10 years includes substan-tial funding for upgrades and expansion of intercity passenger rail service across the country. This potential growth presents Congress with the opportunity to promote rail-bus intermodalism. Legislative priority also needs to be given to preventing possible predatory pricing strategies used in the past by Amtrak to undermine the private intercity bus industry.

Background | Starting in fiscal year 2009, intercity passenger rail has been appropri-ated $13 billion to finance upgrades and

improvements to the nation’s rail network. Of this funding, $8 billion dollars was allocated as part of the American Recovery and Investment Act of 2009. In addition, the high-speed rail state grant program will receive $1 billion a year for five years, ending in 2013. The Administration’s vision for passenger train service is to expand high-speed rail access in 100 to 600-mile corri-dors, as designated by state transportation planners and subject to the approval of the U.S. Department of Transportation (DOT). With new momentum for increased rail service, it becomes vitally important that access to facilities include intermodal trans-portation options. Rail systems are effective at moving large numbers of people from one population center to another; however, pro-vide no flexibility to serve outlying regions. Motorcoach service is flexible and can pro-vide service wherever the national highway system can provide access. The interconnec-tivity of the two modes, by providing feeder service, would seem an easy match. However, passenger rail operators like Amtrak have in the past used access to the public coffers to price local bus service providers out of business. Expansion of rail service could provide a model of how to create connections between modes to the benefit of the trans-portation network.

ABA Position | State and federal rail agen-cies must engage in an intermodal planning process that includes intercity bus along with other mass transportation modes. Further-more, funding for high-speed rail, regardless of the source, should obligate planners at the national, state, and local level to consult with and include intercity bus in design and imple-mentation of facilities. In addition, Amtrak and other rail operators should be prevented from predatory pricing practices that drive intercity bus operations out of business. Predatory pricing schemes destroy the inter-city bus network on which passengers rely on for plasticity of service. Moreover, buses often serve other modes in addition to rail; therefore, losses in motorcoach services

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create a domino effect that dimin-ishes the regional intermodal system. Overall, motorcoach service is a vital component to any successful expansion of passenger rail and should be viewed as a part-ner in extending the reach of the national transportation network.

Charter Rule Enforcement

Issue | Private intercity motor-coach operators face increasing competition from federally sub-sidized local transit agencies that violate federal law. Federal Transit Administration (FTA) regulations prevent transit agencies from using funds to provide charter bus service or regularly scheduled bus service outside urban areas. Yet some local transit agencies contin-ue to offer these services in direct violation of federal regulations.

Background | The Federal Transit Act currently excludes “charter and sightseeing transpor-tation” services from the defini-tion of “mass transportation” for which FTA funding is available. In addition, the Act prohibits a public agency recipient of FTA funds from providing intercity charter bus operations if it will foreclose a private bus operator from providing the same service.

In SAFETEA-LU, ABA was successful in strengthening the laws that pertain to the enforcement of the bus charter rules. Specifically, it prevailed on Congress to mandate that the Secretary of Transporta-tion investigate charter rule violation com-plaints and also have the authority to fine publicly funded transit agencies that violate the charter rules. In addition, Congress, at our urging, mandated that FTA begin a nego-tiated rulemaking proceeding (“Neg. Reg.”) in which public and private bus operators

met and negotiated a new, more equitable bus charter rule. The rule provides clear guidelines on what charter work may be provided by private operators and publicly funded transit agencies, a rational decision and appeals process along with safeguards to ensure that non-profit social service agencies are provided charter service.

ABA Position | ABA seeks full enforce-ment of the FTA’s charter bus rule. ABA rejects congressional action to create carve outs in specific jurisdictions to allow transit operators to perform charter service that is explicitly a function of the private mo-torcoach industry. Publicly funded transit

sPIrIt tours


operations cannot be enabled by circumven-tion of the charter rule to use their access to public coffers to force private industry out of business. ABA supports strong enforcement by FTA of provisions in SAFETEA-LU that require FTA to impose reasonable financial penalties on transit agencies that have estab-lished a pattern of violating the charter rules.

TRANSPORTATION IN THE NATIONAL PARKS

Issue | Motorcoaches bring millions of visitors to national parks and wilderness areas each year and should be regulated in a way that is mindful of the industry’s con-tributions to a vibrant and environmentally balanced tourism program in these areas. However the use of motorcoaches in some parks is unfairly restricted, which nega-tively impacts the viewing experience of the traveling public and the positive congestion

mitigation effects offered by motorcoaches.

Background | As the most fuel-effi-

cient way to travel, motorcoaches are environmen-tally friendly and offer travelers a conservation

minded way to access national

parks. Since each motorcoach carries as

many as 55 passengers, they significantly reduce the

number of cars in the national parks, as well as the associated congestion and emis-sions, thereby helping to maintain the beauty of our National Park System. Simply put, motorcoaches can help the National Park System stay clean.

As part of the growing travel and tourism industry, motorcoach operators are closely tied with (and often are) tour operators

and can be a helpful tool through which the National Park Service (NPS) can promote travel to its Hidden Treasures destinations programs. These operators also offer access to national parks for certain targeted popula-tions who do not currently have full opportu-nity to visit our National Parks including the disabled community.

Too often, though, regulations have the direct effect of punishing motorcoaches, rather than rewarding them for the benefits they provide. Excessive access fees, lack of parking, limited park access and inadequate transportation facilities within and around our NPS all stand in the way of increased motorcoach service. In addition, the practice of requiring passengers to leave a motor-coach for a park service vehicle also stands in the way of efficiency as well as service.

Other issues that prevent service include the competition of public agencies for transportation opportunities in the National Parks. For example, one recent transit agen-cy initiative on the Capitol Mall virtually duplicates the service accomplished by three private operators. The transit agency uses federal funds to undercut the private car-riers’ service. Finally, the effort of the NPS venues to limit the number of group tickets that may be purchased is likewise destructive of the bus industry. The motorcoach industry seeks to be regulated in a way that promotes motorcoach access to our nations’ natural treasures rather than deters it.

ABA Position | ABA supports efforts to expand the use of motorcoaches within the national parks and wilderness areas. We seek opportunity for increased participa-tion of the private sector in the development of mass transportation options for national parks and federally managed areas open to the public. We seek a fair and open process for bidding on service within the national parks. We support the development of a process that includes all modes of transpor-tation in formulating solutions to the problem of congestion in parks and wilder-ness areas.

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Network of Services

nEtwork of SErvicES – ABA Position PAPers 13

ABA Position PapersABA Position Papers

Crown ChArters

networK oF serVICes

Motorcoach services con-nect communities, provide airport, bus, and rail ac-cess to intercity services, commuter programs, and

increase value of public infrastructure in-vestments. As communities look for ways to move more people and goods without build-ing new roads motorcoaches provide flexible, convenient, and cost-effective transporta-tion to develop new routes and schedules, consolidate dispersed residential travel, and connect modes in urban and rural areas. Private operators provide services, which include intercity and regional connector buses, airport shuttle, commuter and transit services, special needs, ADA paratransit, and medical vans with fixed route, bus rapid tran-sit, express, and demand responsive services. These services connect people with schools, doctors, relatives, government services, and work as well as travel and tour opportunities.

The Expansion, Conversion, and Creation of HOV & HOT Lanes

Issue | With the Highway Trust Fund (HTF) facing insolvency and the motor fuel excise taxes representing the primary revenue source for the HTF, new funding streams and paradigms must be found. The High Occupancy Toll (HOT) lane is one of several options being put forward to both increase transportation revenue and control the negative economic effects of congestion.

Background | A high-occupancy toll is a toll enacted on single-occupant vehicles to use lanes or entire roads that are desig-nated for the use of high-occupancy vehicles (HOV). Tolls are collected by staffed toll-booths, automatic number plate recognition or electronic toll collections systems. In some cases, like the 91 express lanes in the

median of the already-congested State Route 91 in California, motorists have been given a choice between toll-free lanes or new lanes on which tolls are charged at different rates according to the time of day. On Interstate 15 in San Diego, single-occupant vehicles are allowed to “buy in” to HOV lanes by paying a toll, essentially converting the HOV lanes to HOT lanes.

The motorcoach is by definition a HOV and, as such, must be able to use HOV lanes (even when traveling empty). Use of the HOV network has allowed motorcoaches greater efficiencies and flexibility in provid-ing service to customers and, in turn, extend-ing the positive benefit provided by motor-coach travel. Specifically, coaches provide the same congestion mitigation benefits as transit buses in that they have the capacity to take up to 55 cars off the road, per mo-torcoach; and are the most fuel efficient and least energy intensive mode of commercial passenger transportation. These valuable contributions to society come at virtually no cost to taxpayers.

The motorcoach industry has supported extension of the HOV network to reduce congestion. It is also clear that in some areas where those networks are underutilized, further congestion mitigation benefit may be achieved by conversion of HOV lanes to HOT lanes for certain vehicles and/or at certain times. However, if instead the con-version serves to make the HOV lanes sig-nificantly more crowded, or if attempts are made to toll high-occupancy vehicles them-selves, this could hinder the efficiency and wide-spread use of high-occupancy vehicles, negatively impacting overall public benefit.

ABA Position | The motorcoach industry supports the construction and expansion of HOV lanes given that they provide additional highway capacity or more efficient allocation of existing capacity. If implemented cor-rectly at the state planning and operations level toll lanes have the potential to increase the efficiency of transportation for the over-the-road motorcoach fleet. This is important

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for effective motorcoach service whether the coach is loaded or empty. To the extent that conversion of HOV lanes to HOT lanes allows HOV lanes to remain viable for high density travel and congestion mitigation, we acknowledge that HOT lane conversion should be considered. Whether high density lanes are designated as HOV or HOT lanes, the motorcoach industry seeks the same exemptions and benefits received in those lanes as other mass transit options, reason-able tracking or tolling processes that do not unduly burden motorcoach operators, and inclusion of motorcoaches in the definition of HOV. Motorcoaches are HOV and are a critical part of the solution to the increasing demand on our transportation system and with congestion and mobility issues.

Tolls and Congestion Pricing

Issue | The funding lapse in the federal Highway Trust Fund (HTF) has forced ex-ecutives and legislatures to look for funding sources outside of traditional tax revenue. One proposed method to address the short-fall is through tolling. In addition, variable tolling methods known generally as peak period or congestion pricing are being con-sidered as a means of reducing congestion. However, tolling by private or public entities could have a significant impact on the motor-coach industry.

Background | The traveling public expects continued investment in the transporta-tion infrastructure in order to maintain and expand our mobility. HTF revenues come largely from fuel taxes and other user fees. With greater engine efficiency and a move towards alternative fuels come fewer tax receipts. Highway officials warn that in the future the country cannot depend on fossil-based fuel taxes to fund its surface transpor-tation system.

Tolling has been proposed as one approach to address the funding shortage; it not only creates revenue but also can potentially

help to manage congestion. Thirty-one of 50 states currently have or are planning tolling projects. However, tolls also raise the possi-bility of creating inequities among transpor-tation users and providers.

One potential concern is the disparity in the ability of all socioeconomic groups to use the road if the tolls aren’t applied in an even-handed manner. Parallel to that issue is a lack of viable transportation options for those who are not able or cannot afford to drive alone. A primary intended result of tolling, congestion mitigation can be further enhanced by reasonable bus tolling practices or negatively impacted by heavy tolling. Tolls should provide incentives for passengers to choose transit buses or motorcoaches over cars. People who can’t afford cars or choose to ride the bus, particularly those in rural areas with fewer transportation options, could be directly and negatively impacted if tolls increase passenger pricing. Increases in pricing can act as a regressive tax on those members of society that can least afford to travel and who are using the transportation system capacity the most efficiently.

Further, tolls should not favor already heavily subsidized public mass transporta-tion over privately operated mass trans-portation. Today, many public transit buses are exempt from tolls. Like motorcoaches, transit buses take cars off the road, improve air quality, minimize pavement wear, and help mitigate congestion. However, privately operated motorcoaches are largely not exempt from tolls. This inequity could grow even worse if tolling expands and conges-tion-pricing programs are implemented. Additional burdens placed on the privately operated public transportation network only serve to create more transportation obstacles to those served cost effectively by motorcoaches.

ABA Position | Tolls should provide in-centives to travelers to choose buses, either publicly or privately owned, over cars. Tolls should not favor already heavily subsidized public mass transportation over privately


operated mass transportation or act as a regressive tax on bus passengers. On those roads where publicly funded transit buses are exempt from paying tolls or variable pricing charges, the same benefit should be provided to motorcoaches.

ADA: Closing the Mobility Gap for Passengers with Disabilities

Issue | In 1998, the Department of Trans-portation (DOT) passed final rules establish-ing accessibility requirements for intercity motorcoaches. To be considered accessible, a motorcoach must now have a wheelchair lift and two wheelchair securement locations. This is an important and costly endeavor for the motorcoach industry, particularly fixed route operators.

Background | The Americans with Dis-abilities Act (ADA) requires accessibility based on vehicle type. In October 2001, the ADA implementation schedule required fixed route motorcoaches to provide lift-equipped service on 48-hour notice until their fleets were fully lift-equipped. The ADA implementation schedule calls for 100 percent lift access by 2012. Charter and tour operators must provide lift-equipped service on 48-hour notice with no requirement for fleet accessibility. The DOT was required to review implementation and actual demand for accessible motorcoach service in 2005. The findings from that review were to go into a report to Congress in 2006 with recom-mendations on amending the accessibility requirements for motorcoaches under the ADA based on a cost benefit analysis. DOT has not completed the use analysis and re-port as of July 2009.

The purpose of the ADA is to provide access to transportation for persons with disabilities needing special accommodation. The requirement for reporting and analysis is to assess the relationship of the accommo-dation to the need for service and whether the rule is a “reasonable accommodation.”

For fixed route services, compliance is indi-cated by the accessibility of the fleet rather than accessible services provided to custom-ers. At the inception of the law it was not clear what a “reasonable accommodation” was and whether the cost of lifts and the use of them indicated a benefit to users that bore a reasonable relationship to the cost to providers to comply with the rules.

The requirement for reporting and lift use analysis was part of the implementation pro-gram. A wheelchair lift adds $40,000 to the cost of a motorcoach, excluding the costs of maintenance, repair, and employee training. According to ABA members the data collected indicates demand for accessible service is substantially less than predicted by the DOT in establishing the ADA requirements. ABA would like DOT to complete the report re-quired in the rules, particularly for fixed route operators because of the high cost of full fleet accessibility and low utilization rates.

Congress authorized funding for motor-coach operators to cover “up to 90 percent” of the incremental costs of ADA compliance. The grant funds available have been a frac-tion of the cost of this vital social interest. The Transportation Research Board has estimated the annual cost of compliance to exceed $40 million. SAFETEA-LU provided approximately $40 million for the five years through 2009.

ABA Position | Congress needs to reau-thorize and extend the compliance-funding program through the life of the next highway and transit bill, and increase the available funding for motorcoach operators to $47 million2 annually to cover the actual costs of ADA compliance for intercity, charter, and commuter services. The motorcoach industry has the obligation of an ongo-ing federal mandate to supply on-demand accessible transportation to the general public. This obligation is part of being a public mass transportation provider. How-ever, crucial assistance in defraying the cost of equipment, training, and maintenance is disproportionately provided to other modes


of transportation. As part of the national transportation system, the motorcoach industry should be afforded the same level of financial support as other public mass transportation modes.

Additionally, Congress should provide funding for the Government Accountability Office to conduct an adequate review of the actual use of accessible motorcoaches as required in the original statute. This re-view should include an alternatives analysis that would assess options for implementing accessibility based on customer needs and uses rather than solely on fleet metrics. Motorcoaches provid-ing commuter services should be eligible for the funds that FTA makes available to public com-muter services for wheelchair lifts. Furthermore, ABA sup-ports legislation that requires the Federal Motor Carrier Safety Administration (FMCSA) to ensure compliance with ADA by denying interstate registration to, and revoking the interstate registration of, bus companies which demonstrate they are unwilling or unable to comply with DOT’s over-the-road bus accessibility regulations.

Dedicated Funding for Intermodal Transportation Facilities

Issue | Federal funding is needed to create a network of intermodal passenger facilities that will provide seamless passenger trans-fers for intercity, commuter, and local public transportation. This would facilitate tour bus access to urban destinations, rural-to-urban

intercity and commuter travel, coordinated transportation, and increased roadway ca-pacity utilization. Intercity bus projects need to be included in public intermodal facilities to integrate intercity bus service into the intermodal chain.

Background | The nation’s surface public transportation system comprises a variety of modes; intercity and commuter bus, intercity and light rail, transit, rural, and medical services.

To be truly effective alternatives to the private automobile, these modes must be linked to each other and to airports. The linkage at intermodal transfer facilities and through travel informa-tion portals needs to deliver seamless transpor-tation to the traveling public.

With increasing pressure on existing road capacity, it is critical to make connections between local transit, commuter, and inter-city services including airports. Customer

2) The TRB study of 2002 concluded that $40 million was an appropriate annual dollar amount for ADA accessibility over the next reauthoriza-tion period. However from 2002 to January of 2008 there has been an average annual rate of inflation of approximately 3.2 percent. Therefore over the six years a total of 19.19 percent inflation has occurred. By January 2008, inflation has reduced the buying value of the initial 40 million 2002 dollars to a net present value of just over $32 million. The historical average annual inflation rate since 1914 is approximately 3.4 percent. It is a reasonable assumption that the average annual inflation rate through the next reauthorization period will fall within the 3.2 to 3.4 percent ranges. Future accessibility grant funding considerations should acknowledge the annual inflation rate as a factor when establishing funding levels.


expectations and taxpayer accountability require broad access to publicly funded stations and facilities. The return on the public investment is increased when the roadway and passenger services maximize their capacity utilization through coor-dinated service and access to facilities. This is true, whether it is buses picking up charters or tour groups arriving by plane or rail, suburban commuters, van services, or rural connectors meeting local transit. A network of facilities that provides access to a spectrum of services increases the value of each of those investments. Suburban areas need park and ride facilities for convenient access to public transportation including commuter bus and rail. Urban areas need central facilities that can co-locate service for local, regional, and national travel.

Two provisions of SAFETEA-LU increased the eligibility of intercity bus as part of intermodal facilities developed with Federal Transit Administration (FTA) capital fund-ing. The first provision, contained in Section 3004 defines capital projects eligible for FTA funding to include intercity bus terminals that are related physically or functionally to public transportation facilities. The second provi-sion contained in Section 3011 sets aside $35 million annually from the FTA Capital Invest-ment Grants bus discretionary program.

ABA Position | SAFETEA-LU provi-sions increase federal funding eligibility for intercity bus projects as part of intermodal facilities and should be fully implemented in accordance with congressional intention and direction. The $35 million set-aside in SAFETEA-LU, has not been tracked sepa-rately. Intermodal facilities funded through joint development agreements and FTA Capital Investment program are not clearly identified. The discretionary program has been earmarked without reference to inter-city passenger needs. FTA should require that federally funded intermodal terminal projects include intercity buses to the maximum extent possible and track access of buses to terminal projects.

Increased Funding for Rural Transportation Needs

Issue | The rural intercity bus program in 49 U.S.C. Section 5311(f ) has helped stem the decline in bus service to rural communi-ties. The FTA Private Match program has to be institutionalized and far greater fed-eral support is needed to ensure that rural communities have adequate connections to the nation’s public transportation system, including air and rail service.

Background | Intercity buses provide daily scheduled service to more than 4,000 com-munities nationwide. This service not only provides essential passenger services, its incidental package express service is the only form of daily, scheduled freight service for many of these small towns. Although motor-coaches serve roughly eight times as many communities as either the airlines or Amtrak, more than 20,000 communities have lost their motorcoach service over the last 30 years.

Congress recognized the need to reverse this trend in SAFETEA-LU by reauthorizing the rural intercity bus program. The rural intercity bus transportation program pro-vides funds for either buses and stations or operations. The 5311(f ) program is funded at approximately $70 million per year through 2009, for rural intercity bus transportation, which doubled what was previously avail-able. This represents 15 percent of a state’s total FTA rural transportation funding. A state can spend more than 15 percent and can only allot less than that amount if after doing a statewide plan and consultation process with private operators the gover-nor finds that rural intercity bus needs are already being met. Furthermore, all eligible bus companies in a given state must be made aware when the state has begun their trans-portation planning process so that these companies may be included in the process and propose projects.

ABA Position | ABA supports the rural intercity bus transportation program. ABA


urges the FTA to track and enforce compli-ance with the SAFTEA-LU intercity bus operator consultation requirements. Any states’ consultation with intercity bus opera-tors must be substantive and any subsequent certification must be rationally related to that consultation. ABA strongly supports the private match program that allows states to expand Section 5311(f ) projects to include local match provided by the cost of the unsubsidized intercity bus service that connects with the subsidized service. This increases the percentage of the net cost of the subsidized service that Section 5311(f ) funds can subsidize from 50 percent to 100 percent and requires collaboration and con-nection for services using the private match process. Finally, any surface transportation reauthorization should clarify that intercity bus operators are eligible “sub-recipients” for Section 5311(f ) funding.

Motorcoach Solutions to Airport Congestion

Issue | Changes are needed to federal planning requirements and funding pro-grams to promote better access to airports for motorcoaches. Motorcoach service is an essential ground transport link and assists in overall congestion relief and clean air on the premises and around airports.

Background | Motorcoaches provide in-tercity, commuter, airport shuttle, and char-ter and tour group connections to airports every day. This service provides an essential ground transportation link in the intermodal chain and alleviates the congestion and pollution caused by automobile traffic into airports. Additionally, many airports do not currently meet air quality attainment levels required under the Clean Air Act. The major source of emissions at airports is not from airplanes, but from cars. Motorcoaches take cars off the road reducing congestion, overall emissions, and fuel consumption at airports and elsewhere.

While most airports work to be self-sus-taining, in practice, they often rely heav-ily on federal funding support. Federally funded airport devel-opment projects are subject to grant as-surances that require airports to provide intercity buses access to their airports to the maximum extent practicable. Yet, too often motorcoaches face barriers to airport access. Those barriers range from excessive fees, denial of curbside access, lack of involvement in the planning process, and systems and infra-structure obstacles to efficient motorcoach service. Furthermore, the fees airports often charge to motorcoach operators violate the federal prohibition on imposing state or local fees on motor carriers of passengers traveling in interstate commerce. These fees, sometimes as high as $50 or more per vehicle per visit, could well run into the tens of thou-sands of dollars per year for a bus company that uses the airport on a regular basis.

ABA Position | Barriers to effective motor-

coach service to airports must be addressed as part of overall airport planning. Airport business models that rely on parking fees and rental car concessions for a substantial portion of their operating budget create a disincentive for airports to invite and develop close linkages with connecting HOV ground transportation. From airport design to down-town transportation centers, facilities must be designed and managed to incorporate access for multiple modes of transportation includ-ing consideration of parking, traffic coordina-tion, and pick up and drop off for motorcoach traffic. Airport authorities should be required to include intercity bus service access and connections in their planning process to alle-


viate congestion, promote clean air and foster security efforts. Bus access improvements at and near airports should be part of the air-port planning process and eligible to receive airport improvement funds.

The Motorcoach Industry Position Essential Bus Service

Issue | The Essential Air Service (EAS) program continues to contract under the pressure of high fuel costs and a slowing economy effectively disenfranchising many rural communities from the broader trans-portation network. However, even with fewer flights serving fewer Americans program costs have increased fourfold from 1996 to 2006.3

Thousands of rural communities need con-nections to the national transportation sys-tem, yet only a handful receive service from the EAS program. In order to sustain their economic vitality, rural communities need alternative airport connectors to give them convenient and reliable hub airport access.

Background | EAS connects approximately 152 rural communities in the United States and its territories to regional and hub airports. The connections are provided by private airlines operating small aircraft on a contract basis. Communities are eligible for funding if they are located between 70 and 750 miles from the nearest hub airport. Within the DOT, the Office of Aviation Analysis admin-isters the EAS program through the Essential Air Service and Domestic Analysis Division.

The division administers the EAS program by examining the number of flights that should be provided to individual communi-ties, the type of aircraft to be used, the carrier that should provide the service and the level of subsidy that the federal government will pay the air carrier providing the community’s air service. The Office of Aviation Analysis has a program budget of more than $100 million for EAS and another $20 million for market-

ing, research, and aircraft acquisition.4

In contrast to EAS, the motorcoach indus-try has been providing nearly unsubsidized service to 14 million rural Americans with-out access to any other means of intercity connectivity. However, this service is primar-ily focused on creating connections with the surface transportation network.

ABA Position | In order to reconnect rural communities that have been isolated from the broader transportation network with the con-traction of EAS, the U.S Department of Trans-portation should establish a pilot program to fund Essential Bus Service (EBS). Private motorcoach operators should be empowered to create connections between non-urbanized areas and hub airports. The EBS program should be flexible enough to allow opera-tors to make stops at intermediate points to expand the accessibility of the traveling public to the transportation network. Furthermore, operators should be given meaningful access to existing hub airports and ground trans-portation facilities to ensure critical linkages across transportation modes.

EBS funding of $50 million per year could be used for activities such as:

(a) Planning and joint marketing for bus transportation.

(b) Capital grants for bus shelters, park and ride facilities, and joint-use facilities.

(c) Operating grants through purchase-of-service agreements, user-side subsidies, and demonstration projects.

(d) Developing and enhancing security pro-cedures for bus passengers connecting to commercial air services.

(e) Enhancing connections between bus service and commercial air services at the airport.

(f ) Coordinating public and private travel in-formation to make it easier to access and use the significant connecting and intercity re-sources provided through the public transit, rail, and the private motorcoach industry.

3) Programs and Options for the Federal Approach to Providing and Improving Airline Service to Small Communities. General Accounting Office, September 2006. 4) Ibid

00 The Motorcoach Industry Position on Idling Regulations









Motorcoach Operations Safety & Security

motorcoach opErationS SafEty & SEcurity – ABA Position PAPers 21

ABA Position Papers

22 ABA Position PAPers – motorcoach opErationS SafEty & SEcurity

MotorCoACh oPerAtIons sAFetY & seCurItY

Motorcoaches are the safest form of ground transpor-tation. Operators, manu-facturers, and government regulators work to develop

safety improvements based on sound sci-ence and best practices. Hours of service, axle weights, driver training, and occupant protection are addressed as part of our initia-tive to keep motorcoaches the safest mode of transportation.

Motorcoach Occupant Crash Protection

Issue | Recently, there has been increasing public focus on questions relating to bus pas-senger safety because of several highly publi-cized crashes and proposed legislation. Much of the attention continues to turn on the mat-ter of whether or not motorcoaches should be equipped with passenger seat restraints.

Background | Motorcoach Safety is a high priority for ABA and the motorcoach indus-try. The government’s own data show that bus travel is the safest form of surface trans-portation. Motorcoaches are buses that carry 30 to 55 passengers with an elevated pas-senger deck over luggage bays. Motorcoaches carry 751 million passenger trips annually5 and over the last decade the fatality rate on motorcoaches was less than half that of all other intercity passenger modes 6.

Existing passenger safety relies on compart-mentalization, motorcoach seats are designed to protect passengers in the event of a crash by compartmentalizing and absorbing the crash impact through collapsing the into a soft cushion. The National Highway Traffic Safety Administration (NHTSA) is undertak-

ing scientific studies to determine the most appropriate means of occupant protection.

The motorcoach tour and travel industry stand ready to work constructively with NHTSA to ensure that any safety propos-als include the scientific review required to produce credible and authoritative research. To enhance the body of knowledge regard-ing motorcoach safety and insure that any changes improve passenger safety; it is necessary to conduct dynamic testing using accepted research test protocols and engage experts in the field to review and analyze the resulting data.

Scientific research must guide policy. The government needs to fund and conduct rigorous research focused on motorcoach engineering and crash scenarios. Without rigorous testing and replicable findings changes in engineering and design of motor-coach safety systems could do more harm than benefit.

Changes to motorcoach glazing, roof structure, passenger safety, and emergency egress need to be looked at in relation to each other. Any change in one area can impact the safety systems in each risk area. Therefore any change in one safety system needs to be made in reference to the other systems.

Safety equipment cannot be bolted onto a motorcoach. Careful research and engineer-ing specific to the vehicle is necessary before changes are made in existing safety systems.

ABA Position | ABA believes we must be certain that in trying to enhance existing occupant protection that we do not inter-fere with or detract from the excellent and effective protections currently provided to passengers. We urge that the recommended testing be conducted and that the program be fully federally funded. We support and have provided technical assistance to NHTSA in this effort. Further as we implement testing and standards ABA would ask that Cana-dian and European testing and standards be incorporated into the review, testing, and development process for NHTSA.

5) Motorcoach Census Update 2006, Nathan (2006) p. 1 6) Federal Subsidies for Passenger Transportation, 1960-2005 , Nathan (2007) p.11


Bus Accident Research

Issue | Current bus accident data research does not adequately reflect the unique char-acteristics of vehicle types and uses vans and over the road buses. This results from the fact that accident data collection systems do not consistently segregate accidents based on the service being provided by the bus at the time of accident and by the specific ve-hicle type. In order to maintain meaningful data to better understand the circumstances involving bus crashes, data collection and reporting must be modified.

Background | Section 224 of the Motor Carrier Safety Improvement Act of 1999 mandates the FMCSA to conduct a study “to determine the causes of, and contributing factors to, crashes that involve commercial motor vehicles.” To implement part of this mandate, FMCSA, together with the Nation-al Highway Traffic Safety Administration (NHTSA) has concluded a truck crash causa-tion study and is now completed two com-mercial bus crash causation studies. Both commercial bus study’s finding complement each other to a large extent. Furthermore, there is significant overlap with some of the truck crash causation findings.

The NHTSA study of 15 passenger vans illus-trates the importance of vehicle characteristics (body type) when determining accident causa-tion factors. The report showed that small vans loaded at, or over their rated capacity often overturned during traffic accidents due to their high center of gravity. The report also illus-trated that small vans are often used for school athletic trips, in addition to the frame-on-chassis design more typical of “school buses.” The recent addition of a “bus use” variable in the Fatal Accident Reporting System (FARS) is a welcome development that begins to address the problem, because it focuses on how the vehicle was being used at the time of the crash. Other specific data research needs include:

n Better data on nonfatal accidents. The NHTSA General Estimates System (GES)

file is the major source of nonfatal accident data, but it distinguishes only school buses from other types of buses. All other buses are classified as “other.” All bus body types, including over-the-road, transit, and small vans must be included.

n Better detail on the events of the crash should be a prior-ity. GES accident type variables cur-rently provide a lot of informa-tion on the relative position and motion of the vehicles prior to the first harmful event in the crash, but addi-tional data, such as the vehicle classifica-tion information from the vehicle identifi-cation number (VIN), should be gathered at the time of the crash.

ABA Position | The FMCSA Commer-cial Bus Accident Causation Study should continue and be conducted as an ongoing national research program due to the relative rarity of serious motorcoach crashes. At a minimum, data collected should specify the vehicle body type (school bus, motorcoach, transit bus, passenger van, etc.) and the type of service being provided at the time of the crash. Forms used by state or federal officials should be standardized across the nation so that all data collected and uploaded into federal databases will be consistent and reflect these baseline details.

Motorcoach Security

Issue | Since the horrific events of Sep-tember 11, 2001, security of public transpor-tation systems has become a national con-cern. Government support is needed to assist


in establishing and funding industry security training protocols and security enhance-ments. The private over-the-road bus indus-try has received approximately $10 million in each fiscal year since FY 2002 through the Congressional Appropriations process. Long-term authorizing legislation to support and enhance motorcoach security programs has been passed, but requires full funding.

Background | The safety of the millions of passengers who ride intercity motorcoaches has been partially addressed through provi-sions in the USA Patriot Act, the REAL ID Act and the 9/11 Commission Act. These statutes, respectively, establish that terror-ist activities in mass transportation systems are federal crimes and require states to issue secure drivers licenses and identification documents, which make certain the apply-ing individual is not a known security risk or has committed disqualifying criminal acts. The 9/11 Act requires intercity bus company provide security training to their employees and have and implement company security policies. TSA regulations to this effect are expected to be promulgated early in 2010. Furthermore, prior federal security grants have provided operators with critical sources of capital to upgrade their company security programs.

Grant funds have allowed the ABA, in conjunction with others, to develop and deliver a detailed security training program and security planning template to the entire industry. The Transportation Security Administration (TSA) has determined that these security training and planning materi-als will establish the federal security baseline for our industry in the forthcoming security regulations.

In FY 2008, the Office of Management and Budget (OMB) zeroed out the Intercity Bus Security Grant budget line from the Administration’s budget recommendation to Congress. In effect, OMB made a blanket determination that no matter how worthy the bus industry’s security need no further federal grants would be available.

ABA Position | In order to develop a comprehensive national security program, the public and private sector must continue to work together to develop and keep cur-rent a sound public policy that embraces realistic strategies, laws or regulations. Towards that end, ABA supports long-term authorizing legislation, which will provide “Over-the-Road Bus Security Assistance” through continued security funding. This successful program should remain at the forefront and distinct from other efforts to provide preparedness. Congress needs to continue to fully fund the intercity bus security grant program as suggested in the 2010 TSA Motorcoach Threat Vulnerability Analysis. If Congress does continue funding security grant, then DHS must set priorities for funding that address the greatest threat to bus passengers and others. The grant applications must stand or fall on their own merits and not allow significant portions of the industry to go without security funding. With new planning requirements emerging related to federal security policy, training, and audits of motorcoach companies and recipients of security funding, ABA will work to ensure that training is made available to assist companies in preparing appropriate planning documents and that federal entities reviewing company security plans adopt an industry specific approach. Assurances will need to be developed to protect the integrity of the plans implemented by companies and ABA will look to be involved in that process.

Motorcoach Axle Weight Regulations

Issue | Over-the-road buses (OTRB), like traditional transit buses, have been carrying progressively more weight on each axle due to government mandates, such as new engine exhaust reduction technology and wheel-chair lifts required by the ADA, as well as market driven amenities. As a consequence, fully loaded OTRB approach, and sometimes may exceed, the federal axle weight restric-


tions of 34,000 pounds on the tandem axle (with no single-axle allowed to carry more than 20,000 pounds).

Background | Since 1982, federal law has prohibited (with certain exceptions) any vehicle that exceeds 80,000 pounds gross vehicle weight from using the interstate highway system. The law also prohibits any one axle from carrying a load in excess of 20,000 pounds, and tandem axles cannot exceed 34,000 pounds gross weight.

Intercity motorcoaches and trucks are both defined as “commercial motor ve-hicles” under federal law, and are regulated the same with respect to size, weight, and length regulations.

However, motorcoaches and trucks are significantly different: there are approxi-mately 40,000 motorcoaches currently operating on our highways, compared with nearly 1.5 million trucks; the gross weight of a fully loaded motorcoach rarely exceeds 55,000 pounds, while a truck may weigh as much as 80,000 pounds fully loaded; motor-coaches have inherent design restrictions that limit them to a maximum of three ax-les, while a tractor-trailer combination may have five or more axles; and unlike trucks, the TAG (non-drive) axle of a motorcoach has only two tires, and is not designed to carry the same load as the drive axle, which has four tires.

For several years ABA endeavored to have the private bus industry subject to the same axle weight exemption as the transit buses. A provision in SAFETEA-LU granted us this exemption. The fiscal year 2006 trans-portation appropriations legislation in-cluded a provision that prevents individual States from imposing lower axle weight limits on their portions of the interstate highway system, which a few states used as a reason to levy fines against private bus operators.

ABA Position | ABA supports continued exemption of the private motorcoach industry from federal bridge formula axle weight limits.

Driver Qualification Information

Issue | During the hiring process, a mo-torcoach operator may not have access to critical information necessary to determine a driver’s fitness to work. There are two as-pects to this evaluation process fitness of the applicant through background and medical checks and commercial driver’s training and endorsement.

Background | Whether or not a company hires a driver depends on many factors. What is the candidate’s prior driving and accident history? Have they ever tested positive for drug or alcohol use? Do they have a crimi-nal record? Are they physically qualified to drive? Do they have the experience and training needed to be a safe and successful driver? The ability to evaluate these factors is difficult because of the lack of verifiable information provided by the applicant, their prior employer(s) or state agencies.

SAFETEA-LU required the establishment of both an FMCSA-managed medical review board and a national registry of DOT medi-cal examiners. In providing this authority, Congress also allowed the medical examiner community the option of “self-certifying” to the FMCSA their understanding of, and duties under, the regulations. The FMCSA


has published a notice of proposed rulemak-ing, but has yet to issue final rules even with strong Congressional pressure to do so.

Through court ordered rule making, FMCSA published a notice of proposed rulemaking for new entrant training and CDL training standards. The new entrant final rules have been published and were strongly supported by ABA and the BISC. However, there are significant problems with the proposed CDL training standards. ABA and the BISC submitting comments detailed comments to the agency’s docket.

The motorcoach industry has driver train-ing curriculums that have served the in-dustry well. The new proposed rules are not based on a successful motorcoach driver-training program but on truck driver training and would, if not changed, make it extremely difficult and risky for operators to train drivers in-house. The new rules shift the assessment of competence away from the state agencies awarding the com-

mercial driver’s license endorsement and onto the organization or company providing the training.

ABA Position | ABA supports imple-mentation of the SAFETEA-LU provisions regarding medical examiners and the reg-istry of qualified medical providers. ABA opposes the concept of medical providers’ self-certification. ABA also believes that: medical review officers should be required to post positive drug and alcohol results onto a central federal database, which can

be accessed by a motor carrier during the hiring process. This provision has been included in the House version of the upcoming Highway Reauthori-zation bill.

ABA supports a national, cen-trally controlled federal database. These databases would contain all critical safety and security infor-mation on all CDL holders. This information would be accessible to motor carriers during the hiring process.

Electronic On-Board Recorders (EOBRs)

Issue | Current law defines an Electronic Onboard Recorder (EOBRs) as “an electric, elec-tronic, electromechanical, or mechanical device capable of recording driver’s duty status information accurately and au-

tomatically. The device must be integrally synchronized with specific operations of the commercial vehicle in which it is installed. At a minimum, the device must record engine use, road speed, miles driven, the date and time of day.” Though this system has not been widely tested in the motor-coach industry, the FMCSA is considering its application for motorcoaches to monitor driver hours of service.


Background | On July 16, 2004, the United States Court of Appeals for the DC Circuit Court ruled on a petition filed by Public Citizen, the Advocates for Highway and Auto Safety, and the Insurance Institute for Highway Safety against the Department of Transportation (DOT), forcing them to vacate the new hours-of-service rules. Ques-tions raised by complainants in this action prompted the FMCSA to issue an Advance Notice of Proposed Rulemaking (ANPRM) on October 19, 2004, regarding the use of EOBRs to document compliance with hours of service regulations.

The motorcoach industry is fully commit-ted to providing a safe and secure environ-ment for its passengers and personnel and is involved in a variety of efforts (training, equipment, and facility modifications, com-munications systems, etc.) to promote safe, responsible operations. The intercity bus industry possesses an unparalleled safety record, and has one of the lowest hours of service violation rates among major surface transportation modes.

The current generation of EOBRs, many of which allow for vehicle tracking capabili-ties using global positioning system (GPS) based technologies, cost between $700-$3,500 per unit. There can also be an initial investment in GPS system software ranging from $10,000-$80,000 in capital costs for a motorcoach company. A limited number of operators have employed these systems to provide a more detailed reporting of their ve-hicle location, use, driver activity, and to help dispatch centers reroute and navigate drivers around congested thoroughfares. However, they report the need to invest significant additional time and effort to understand, maintain and review the electronic logs and their requisite printed-paper backups.

ABA Position | ABA supports the imple-mentation of EOBR technology once testing has established a link between enhanced safety and use of EOBRs. ABA also believes implementation of EOBRs must be based on a minimum federal standard that is limited to

hours of service (HOS) compliance. Further-more, compliance with HOS must remain the responsibility of the driver even when using an electronic log book. Motor carriers using compliant EOBRs should be relieved of the burden of retaining supporting documents for verification of driving time. Given the high capital costs of implementation the federal government should provide some form of tax credit or grant to help reduce the burden on small business. The motorcoach indus-try strongly supports implementing new safety technologies that have been tested and proven to show meaningful improvements in vehicle and driver safety.

Hours of Service Changes for Intercity Motorcoach Drivers

Issue | FMCSA enacted sweeping changes to the driver’s hours-of-service (HOS) regulations for truck operations. Bus com-panies have been allowed to continue to follow the old rules in part because of the industry’s superior safety performance and due to the failure of the FMCSA to conduct any meaningful bus driver fatigue studies prior to the promulgation of the “truck” rule changes. FMCSA has stated that they intend to conduct studies on bus operations and bus driver fatigue and that they could consider changing the HOS rules if warranted.

Background | Currently motorcoach driv-ers in the United States must comply with the following HOS rules: 1) A driver may drive up to 10 hours, then must have eight consecutive hours off duty; 2) A driver may remain on duty up to 15 hours, including driving and on-duty time. After this limit is reached, the driver must have eight consecu-tive hours off-duty; 3) A driver may not drive after having been on-duty for 70 hours in any consecutive eight-day period.

In Canada, things turned out differently. North of the border new HOS rules for truck and bus drivers come into effect on Janu-ary 1, 2007. The Canadian rules are very

28 ABA Position PAPers

similar to the new U.S. truck rules. All U.S. based passenger carriers traveling across the northern border after the effective date must train their personnel accordingly and be prepared to deal with the scheduling changes the new Canadian rules will bring about.

The FMCSA’s decision to carve the bus industry out of the HOS rules validates the following industry conclusions:

Trucks and buses are not the same type of vehicles, and operate differently because:

n Drivers in intercity, fixed-route service operate on highly regular schedules. Bus service is characterized by frequent, regu-lar terminal stops, and loads of passengers, not freight. Schedules are set to minimize time away from home; with drivers rarely spending more than one night at a time away from home.

n Charters and tours bus companies plan itineraries with plenty of rest time for driv-ers while allowing passengers to visit the attractions they desire. Most motorcoach drivers are paid by the hour, whether they are driving or not, not by the mile.

n Intercity bus drivers stay in hotels, or sleep in their own beds at night. Most multi-day charters operate in conjunction with pas-senger’s circadian rhythms—passengers do not like spending nights in motorcoaches—and are therefore not commonly on the road all night.

There is currently no scientific evidence to support changing the HOS rules for inter-city bus drivers because the FMCSA has no evidence that fatigue is a problem in the intercity bus industry and shows no research to support the proposed changes.

ABA Position | ABA believes that bus driver HOS rules should not be altered un-less solid evidence can be presented that justify such changes. ABA also supports continued research into fatigue as a factor relating to motor vehicle accidents.

Safe and Fair Implementation of NAFTA

Issue | ABA supports timely, safe, and re-ciprocal implementation of the North Ameri-can Free Trade Agreement (NAFTA). Imple-mentation of NAFTA must be conducted in a way that ensures reciprocity for U.S. motor-coach operators and highway safety.

Background | The NAFTA surface transportation provisions are designed to eliminate restrictions in all three NAFTA countries that limit access for and invest-ment in transportation companies. For buses, changes in access refer to lifting cross-border restrictions on charter and tour buses, a pro-vision that has already been implemented, and a reciprocal lifting of restrictions on regular route carriers, which has yet to be implemented. In terms of new investment, the U.S. is to allow 100 percent investment in bus companies owned by Mexicans while Mexico is to allow 51 percent United States ownership of Mexican companies in 2001 and 100 percent in January 2004. It is im-portant to note that Mexican-owned U.S. bus companies will be allowed to provide both domestic and international service in the United States.

The U.S. Congress has repeatedly post-poned implementation of provisions of the North American Free Trade Agreement (NAFTA) with respect to Mexico-domiciled truck and scheduled bus service and con-tinued a blanket moratorium on processing applications for authority by Mexico-domi-ciled motor carriers to operate in the United States beyond the commercial zone along the border. On February 6, 2001, a NAFTA dispute resolution panel ruled that the blan-ket moratorium violated the United States’ commitments under NAFTA. The DOT is now preparing for the implementation of NAFTA. At Brownsville, Texas, 350 buses a week travel across the Los Tomates/Veter-ans Bridge, yet buses are checked only one day a month. There must be vigilant enforce-ment of passenger carrying vehicles at the



border to ensure safety. Yet, the Federal Mo-tor Vehicle Safety Standards (FMVSS) seek to ensure that vehicles driven on the public roads and highways of the United States, are manufactured so as to reduce the likelihood of motor vehicle crashes and of deaths and injuries when crashes do occur.

To ensure compliance with FMVSS, manufacturers of motor vehicles must certify compliance with all applicable safety standards and permanently affix a label to each vehicle stating that the vehicle complies with FMVSS at the time of manufacture. However, DOT has delayed the implemen-tation/enforcement of that requirement. This delay could potentially allow unlabeled or non-compliant vehicles to cross the border. The recently passed SAFETEA-LU contains a provi-sion that requires the FMCSA to examine the compliance of both Mexican and Canadian vehicles with respect to their compliance to FMVSS and report the results back to the Congress within one year from the enactment date of the statute. It further requires the Department of Transpor-tation’s Inspector General to provide Congress comments and observations on the scope and methodology of the FMCSA study within four months from the date the study is submitted.

Furthermore, the Motor Carrier Safety Improvement Act of 1991 mandated that the DOT apply the FMCSR (except for drug and alcohol and CDL requirements) to small pas-senger vans or “camionetas.” ABA believes it is imperative that the DOT proposed rule be finalized and an enforcement plan put into place prior to the opening of the border.

Enforcement of other issues includes checking for compliance with the FMCSR, including operating authority, a drivers “Licensia Federal” (CDL equivalent), HOS rules, ADA requirements, etc. Finally, an expedited rulemaking is needed to establish

a facility audit requirement prior to the issu-ance of operating authority to new entrants to the U.S. market, regardless of whether they are based in the United States or Mex-ico. DOT proposed that new entrants oper-ating in cross border service from Mexico be audited within 18 months of receiving authority. This rule does not apply to those companies based in the United States with Mexican ownership. ABA believes that an audit, in advance, is the only way to ensure that new passenger operations show under-standing and compliance with the Federal regulations prior to beginning operations.

ABA Position | ABA continues to be sup-portive of NAFTA, so long as it is conducted in a way that ensures reciprocity for U.S. motorcoach operators and ensures highway safety. ABA supports the FMVSS border check. However, checks should include both an electronic database search as well as a visual inspection. The DOT database should be used to ensure that the carrier has operat-ing authority and complies with all pertinent insurance requirements. While visual in-spections are limited at a minimum, vehicles should only be allowed entry if they can show visible proof of compliance with the FMVSS through a manufacturer’s affixed certifica-

BoLt Bus


tion label or plate. Further, border officials should be trained to detect counterfeit and/or fraudulently applied certification labels. ABA will carefully monitor the FMCSA’s efforts in conducting the study and will urge the agency to complete its efforts within the mandated time frame. We will also continue to push for increased border inspections. We believe that a two-pronged test is the only way to ensure that safe and secure vehicles operate on U.S. roads and highways.

The Motorcoach Industry Position on Information Sharing & Analysis Centers (ISAC)

Issue | Information Sharing & Analysis Centers (ISACs) have been established among common industries to share intel-ligence information from government and industry sources regarding potential security threats.

Background | Several associations have joined an established ISAC or are consid-ering future involvement in or establishing their own ISAC. The American Associa-tion of Railroads (AAR) currently hosts a Surface Transportation ISAC working with a contractor, EAW. Funded by the Federal Transit Administration, the American Pub-lic Transportation Association has created

a public transportation “node” within the AAR ISAC.

The American Truck-ing Associations es-

tablished an ISAC connected to its Highway Watch safety call cen-ter. Government funding was appropriated in the amount

of $20 million for this effort for

training, an opera-tions center, a call cen-

ter and the ISAC itself. There is currently no mandate for indus-

tries to enter into an ISAC. It’s possible that ISAC participation could be mandated in the future and there is an expectation that the Transportation Security Administration will ultimately serve as the host or sponsor for a surface transportation industry ISAC with individual nodes representing each service sector. The motorcoach industry is fully committed to providing a secure envi-ronment for its passengers and personnel and is involved in a variety of efforts (train-ing, equipment, and facility modifications, communications systems, etc.) to promote security. For an industry not previously faced with these challenges, this is a significant ef-fort, both in depth and scope, and one that is of immediate importance.

ABA Position | ABA supports participation in ISACs on a company voluntary basis and will invite member operators to consider participation in ISACs. ABA will provide security alerts and information on a pass-word-protected portion of our web site as appropriate. However ISAC involvement is just one item on a long list of security priorities we face, and one that presents multiple concerns for consideration: 1) limited communication infrastructure exists within or between bus companies to form an effective interface with an ISAC; 2) regulatory limits placed on what “secu-rity sensitive information” (SSI) may be passed along to company personnel; 3) the federal government should host and fund the ISACs—not industry; 4) ISACs must not create confusing and perhaps detri-mental layers of communication between companies, federal, state and local law enforcement entities; and, 5) ISACs in and by themselves should not have the ability to call for a partial or complete shutdown of the system based on perceived security threats. Such non-governmental powers have the potential to cause major disruptions and could generate financial havoc within an affected industry. Motor CoACh

InDustrIes

EnvironmEntal travEl choicE – ABA Position PAPers 31

ABA Position Papers

EnvironmentalTravel Choice

Motor CoACh InDustrIes

enVIronMentAL trAVeL ChoICe

According to studies by the Union of Concerned Scientists and MJ Bradley and Associates motor-coaches are the most energy- and carbon-efficient form of

mass transportation from 100 to 1,000 miles.In 2007, the industry on average achieved

206.6 passenger miles per gallon more than seven times the efficiency of a single passen-ger automobile and more than six times the efficiency of a transit bus. In addition motor-coaches are one of the most carbon efficient forms of transportation emitting only 50 grams per passenger mile compared to 378 grams for a single occupancy vehicle.

According to a study by the Texas Trans-portation Institute motorcoaches save the traveling public 1.2 billion hours of wasted time and 650 million gallons of fuel by alleviating congestion on our nation’s surface transportation network.

The Motorcoach Industry Position on Idling Regulations

Issue | Stringent state and local enforce-ment of excessively restrictive idling rules are resulting in significant fines for motor-coach operators and forcing them out of cities that rely on motorcoach passengers for tourism revenue. Practical safety consider-ations, inadequate parking facilities, and the unique positive impact motorcoaches have on the economy and on the environment have been overlooked by destinations impos-ing these rules.

Background | ABA believes aggressive ticketing for motorcoach idling is short sight-ed and detrimental to the safety and wellbe-ing of passengers and pedestrians alike and fails to recognize the positive impact mo-torcoaches have on the economy and on the environment.

Motorcoaches have a positive impact on the environment, taking cars off the road and mitigating congestion. Motorcoaches are fuel efficient, delivering more than 146 pas-senger miles per gallon of fuel, yielding more people-moving efficiency per BTU than any other mode. And since 1998, new Environ-mental Protection Agency (EPA) standards applying to particulates and NOx levels have resulted in reduced emissions of 90 percent over 1998 levels.

Idling is a necessary and, in fact, critical step in preparing a motorcoach for operation. 49 USC 14101 (a) requires that motor car-riers of passengers licensed to operate in interstate commerce must provide “safe and adequate service, equipment, and facilities.” To meet this service standard, it is necessary for a motorcoach to idle in order to:

n Pump up the motorcoach air pressure systems to ensure brake performance as required by 49 CFR 393.52.

n Utilize ADA mandated wheelchair lifts. n Operate the heating or air conditioning

system to warm up or cool down the inte-rior of the motorcoach.

As mentioned above, Federal regulations require that brakes must be able to exert appropriate force in order to effectively stop the vehicle (49 CFR. 393.52). For the air braking system in motorcoaches, idling time is necessary to build up sufficient air pres-sure to meet the standard laid out in 49 CFR 393.52. Drivers should not be compelled to leave the curb before proper brake-system air pressure is achieved, endangering pe-destrians and passengers. Further, it is sometimes necessary to idle a bus in order to assess vehicle systems, and perform mechan-ical repairs. Even this critical effort can run afoul of local idling regulations.

Additionally, as the ADA is implemented, operators will require sufficient idling time to power up and insure the proper operation of the wheelchair lift for passengers with dis-abilities using the lift. A three- or five-minute idling restriction is simply not sufficient to

32 ABA Position PAPers – EnvironmEntal travEl choicE

EnvironmEntal travEl choicE – ABA Position PAPers 33

ensure the safe and efficient transportation of our passengers.

For reasons of safety, health and comfort, drivers need sufficient idling time to properly heat or cool the motorcoach to an appropriate temperature before boarding can begin. This is a particular challenge with groups of senior citizens traveling in times of extreme hot or cold temperatures. The Federal regulations state, with regard to regular route carriers that, “a carrier shall maintain a reasonable temperature on each bus” (49 CFR 374.313). In extreme temperatures, it can take a sig-nificant amount of time to bring the coach to ambient temperature. A coach takes as long as 45 minutes for the engine to fully cycle result-ing in a heating or cooling effect of 15 degrees. Temperature in a parked coach can reach as high as 130 degrees in the southwest or as low as freezing in parts of the northeast. Given a change of 15 degrees per 45 minutes of engine cycling time, the necessary heating or cooling time required in these cases could easily take more than one hour.

In an effort to quantify the congestion mitigating and environmental solutions that motorcoaches present, ABA has part-nered with the Department of Energy (DOE), DOT, and the EPA to conduct a study evaluating the true effects of mo-torcoach idling. This study, published in June of 2006, has shown that when forced to circulate or creep through traffic at low speed, a motorcoach expends twice as much fuel and produces forty percent more emis-sions as compared to stationary idling. This data has also provided a measuring stick for the unintended consequences induced by the stringent regulations limiting stationary idling in lieu of long-term parking solutions. Given the federal guidelines for safe opera-tions, motorcoach operators are at times placed in an untenable position because of these regulations, either choosing to avoid a city or locality all together, or being forced to circulate in “creep” mode, which has been shown to have an even more adverse environmental and fuel consumption effect than stationary idling.

The EPA has published a “State Idling Legislation Model,” which appears to provide the levels of flexibility the industry has asked for. Both Pennsylvania and New Jersey have adopted the model language as it relates to motorcoaches.

ABA Position | All local and state or-dinances should be modified to allow a motorcoach operator the latitude to idle a bus to comply with federal statutes and regulations and to ensure the safety, health and comfort of its passengers. Therefore ABA proposes that new statutory language is necessary along with modifications to the FMCSR to allow a motorcoach operator sufficient time to idle to ready vehicle sys-tems. ABA believes that in accordance with the EPA model idling legislation operators should be allowed reasonable and prudent idling time to allow for safety systems to be in operating condition. Furthermore, mo-torcoach operators should have access to parking facili-ties to ensure that drivers are not forced to circulate and that idle times are kept to a minimum.

Biodiesel Fuel Additives vs. New Fuels and Engines

Issue | Although the motorcoach industry is already an environmentally friendly and fuel-efficient mode of transportation, policy-makers are considering new strategies to address air quality and energy sourcing. These combined issues could potentially have a dramatic effect on motorcoach operations.

Background | On December 21, 2000, the EPA issued a final rule calling for a reduction in sulfur content in diesel fuel by 97 percent. This required fuel refiners to reduce sulfur content in diesel fuel from 500 parts per mil-

34 ABA Position PAPers – EnvironmEntal travEl choicE

lion to 15 parts per million. However, even beyond this ambitious new

regulation there has been increasing activity in various states, primarily states with a large agricultural base, to require diesel fuel sold in the state to include a component percent-age of bio-diesel as an additive. The reasons given are usually as follows:

n The nation’s air quality is improved. n American dependence on foreign oil

sources is reduced.n American farmers are given a badly

needed boost. n Bio-fuel blend stocks are a renewable

resource.

Unfortunately, serious questions and concerns exist on the use of bio-diesel as a viable additive to petroleum diesel fuel that should not be dismissed by government or the public in a rush to obtain the above described benefits. Since the major diesel engine manufacturers entered into a contro-versial consent agreement with the Depart-ment of Justice, the EPA, and the California Air Resources Board at the end of the last administration, fuel and engine producers have been under a court mandated fast track to dramatically reduce both particulate

matter (PM) and NOx by 2007 and 2010 respectively. All development efforts have been solely focused on developing engine and exhaust after-treatment that will work using an ultra-low sulfur content diesel fuel. However, the effect of introducing bio-diesel blends into this carefully developed mix is not known. No testing has been reported by either the engine/exhaust after-treatment manufacturers or by the fuel refiners or by the bio-diesel producers. Congress noted this lapse when it passed the Energy Policy Act of 2005. Congress has called for a study to determine the effect on the new series engines of adding bio-diesel additives to

ultra-low sulfur diesel fuel. The administration report answer-ing these questions was to have been submitted to Congress by the summer of 2007; however, to date, this study has not been completed.

ABA Position | New diesel engines and their associated exhaust after-treatment devices have been specifically designed and tested for pure ultra-low sulfur diesel fuel. What effect bio-diesel fuel added to ultra-low sulfur diesel fuel will have on this new engine technology is not presently known. In 2007, the DOE was to have submitted a report to Congress on what effects bio-diesel fuel blends

will have on new engines and exhaust after-treatment devices.

ABA encourages the completion of the congressionally mandated research and report prior to any federal, state or lo-cal government actions. ABA believes it would be fatally premature to mandate the use of bio-diesel blends through either policy or law if, by such action, there is a risk of making federally emission compli-ant engines or vehicles non-compliant or potential damage to engine warranties or components.

EnvironmentalTravel Choice










The American Bus Association Foundation, along with independent researchers and third-party organizations, annually produce a variety of research pieces on the motorcoach industry. In this section, we have compiled executive summaries and key fi ndings of projects relevant to our industry. If you wish to view the full treatise, please visit www.buses.org.

Research & Reference

37 Motorcoach Census 2008

40 National Economic Impact

42 Modal Subsidy Report

48 Comparative Energy

reFerence section 35

36 ABA Position PAPers

MotorcoAch censUs 37

Paul Bourquin: Economist and Industry Survey Analyst, December 18, 2008

motorcoach census

A Benchmarking Study of the Size and Activity of the Motorcoach Industry in the United States and Canada

Executive Summary

Motorcoach Census 2008 is a benchmarking study commissioned by the American Bus Association (ABA) to measure the size

and activity of the motorcoach transporta-tion service industry in the United States and Canada in 2007.

The study provides information on the scope and impact of the motorcoach industry that cannot be found elsewhere.

Industry size is measured by the number of motorcoach carriers and the number of motorcoaches they operated. Activity is measured by the number of passenger trips provided, passenger miles, services provided, motorcoach miles traveled, fuel consumed, and employment.

In 2007, the motorcoach industry in the United States and Canada consisted of just over 3,400 companies that operated 33,536 motorcoaches. In the United States, 3,137 companies operated 29,325 motorcoaches and, in Canada, 295 companies operated 4,211 motorcoaches.

Passenger Trips | The motorcoach indus-try provided about 750 million passenger trips in 2007. One in four of these trips were provided by large companies that operated 100 or more motorcoaches, 22 percent by mid-size companies operating 25 to 99 mo-torcoaches, and 50 percent by small compa-nies operating fewer than 25 motorcoaches.

In providing these trips, the industry moved individual passengers a total of 65 billion miles in 2007.

Services | The services offered by the industry are diverse. Nearly all motorcoach companies (96 percent) provided charter service in 2007, just over half provided tour service, one-sixth provided sightseeing, one-seventh provided airport shuttle, one-eighth provided scheduled service, one-ninth provid-ed special operations, and 5 percent provided commuter service. Nearly half of motorcoach service mileage was for charter service and about one-quarter was for scheduled service.

Companies | The vast majority (95 per-cent) of motorcoach companies were small and operated fewer than 25 motorcoaches. They operated a total of nearly 16,000 motorcoaches, provided nearly 380 million passenger trips, and accounted for about 40 percent of motorcoach mileage. Mid-sized companies, those that operated 25 to 99 motorcoaches, had a total of 7,000 motor-coaches, provided 168 million passenger trips, and had 20 percent of the industry’s motorcoach mileage. Large companies that operated more than 100 motorcoaches ac-counted for just over 30 percent of the indus-try’s motorcoaches, provided 27 percent of the industry’s passenger trips, and 39 per-cent of the industry’s motorcoach mileage.

Employment | The motorcoach industry provided jobs to 118,000 people in 2007,

62,000 full-time and 56,000 part-time. On average, a motorcoach company pro-vided 34 jobs or 3.5 jobs per motorcoach. More than half of the jobs were with small companies that operated less than 25 motorcoaches, nearly 20 percent with mid-sized companies that operated 25 to 99 motorcoaches, and 30 percent with large companies that operated 100 or more motorcoaches.

Fuel Efficiency | Motorcoaches move people with little fuel. In 2007, the average fuel efficiency of a motorcoach was 5.7 miles per gallon of fuel. With this fuel efficiency, a motorcoach carrying the industry average of 36 passengers achieved 205 passenger miles per gallon of fuel in 2007.

Motorcoach Use | On average, a motor-coach provided 22,000 passenger trips in 2007, moved individual passengers a total of 2 million miles, employed 3.5 people, used 10,000 gallons of fuel, and traveled 56,000 miles. More than half (56 percent)

of its service mileage was for charter, tour, and sight-

seeing services and 44 percent was for

fixed-route servic-es (airport shut-tle, commuter, scheduled, and special opera-tions).

This study reveals through

numbers the scope and impact

of the motorcoach transportation industry

in the United States and Canada. It shows an industry that serves all people, especially students and seniors, and that moves people with great fuel ef-ficiency. It shows an industry that provides a variety of services, including charter, tour, and sightseeing services, which are of vital importance to the travel and leisure

industries, and intercity and commuter services, which are essential components of the passenger transportation systems in the United States and Canada.

Definition of the Motorcoach Industry

The industry consists of private-sector organizations that lease/own and operate motorcoaches and offer motorcoach trans-portation services to the public, including to private- and public-sector organizations on a contract basis. The industry includes, for example, motorcoach transportation companies that are hired on a contract basis by state or city transit authorities to transport commuters on motorcoaches. The industry excludes, however, governments, transit agencies, or other public-sector organizations that lease/own and operate motorcoaches and offer motorcoach trans-portation services to the public. The indus-try also excludes private- and public-sector organizations that lease/own and operate motorcoaches just for their own use, such as businesses that operate motorcoaches to shuttle their employees.

Definition of a Motorcoach

For this study, a motorcoach, or over-the-road bus (OTRB), is defined as a vehicle designed for long-distance transportation of passengers, characterized by integral con-struction with an elevated passenger deck located over a baggage compartment. It is at least 35 feet in length with a capacity of more than 30 passengers. This definition closely matches the definition of an OTRB written into U.S. law, namely “a bus characterized by an elevated passenger deck located over a baggage compartment” (Section 3038 of Public Law 105-178, 49 USC 5310 note). This definition of a motorcoach excludes the typical city transit bus, which is designed for urban and suburban routes, and city sight-seeing buses, such as double-decker buses and trolleys.

38 MotorcoAch censUs

MotorcoAch censUs 39

selected results of Motorcoach census 2008

1) Size of the Motorcoach Industry in the United States and Canada in 2007

in the United stAtes

numbEr oF carriErs 3,137

moTorcoachEs 29,325

in cAnAdA

numbEr oF carriErs 295

moTorcoachEs 4,211

GrAnd totAl

numbEr oF carriErs 3,432

moTorcoachEs 33,536

2) Motorcoach Industry Activity in the United States and Canada in 2007

PassEngEr TriPs 751 million

PassEngEr milEs 65.496 billion

milEs TravElEd 1.880 billion

milEs TravElEd carrying PassEngErs (serVICes MILes) 1.798 billion

gallons oF FuEl consumEd 331 million

EmPloymEnT 118,000

3) Motorcoach Operating Ratios for 2007

PassEngEr TriPs PEr moTorcoach 22,000

PassEngEr milEs PEr moTocoach 1.953 million

milEs TravElEd PEr moTorcoach 56,000

sErvicE milEs TravElEd PEr moTorcoach 54,000

PassEngErs PEr sErvicE milE 36

milEs PEr gallon oF FuEl 5.7

PassEngEr milEs PEr gallon oF FuEl 205

EmPloymEnT PEr moTorcoach 3.5

4) Demographics of Motorcoach Passenger Trips

sTudEnTs / sEniors (55 yEars or morE) / oThEr 33% / 32% / 35%

40 nAtionAl econoMic iMPAct

national Economic impact

The Motorcoach Tour and Travel Industry Creates Jobs in the United States

United States companies that provide motorcoach services to intercity travelers and group tours are a critical part of the country’s economy. Motor-

coach operators, along with the companies that supply services and materials to them, provide well-paying jobs in the United States and pay significant amounts in tax to local, state, and federal governments.

The Motorcoach Industry is a Crucial Part of the Country’s Economy

n Companies in the United States that provide motorcoach services to tour-ists, travelers, and commuters employ as many as 127,600 people in the country. In addition, companies that supply ser-vices to motorcoach passengers, such as hotels, restaurants, and entertainment venues employ as many as 480,600 additional people in the United States.6

n These are good jobs, paying an average of $31,260 in wages and benefits. And today, every job is important.

The Economic Benefit of the Motorcoach Travel Industry is Felt Throughout the Country

n Not only does the motorcoach travel industry create good jobs in the United States, but the industry also contributes to the economy as a whole. In 2009, about 147,400 people worked for firms that supplied goods and services to companies

working with motorcoach passengers. These include a wide range of companies from wholesalers, to accountants, to fuel-ing stations. All told, nearly $112.7 billion in total economic activity in the United States can be attributed to the motorcoach tour and travel industry.

n In addition to providing good paying jobs for thousands of workers in the United States, motorcoaches are the most fuel- and carbon-efficient mode of passenger transportation. Motorcoach travel averages 206 passenger miles per gallon compared to commuter rail at 92, transit bus at 31, personal automobiles at 27 and hybrid cars at 46 passenger miles per gallon.

economic impact of Motorcoach-Based travel in the United states

Direct Supplier Induced TOTAL

Jobs (FTE) 608,200 147,400 301,200 1,056,800

WagEs $19,010,656,500 $7,808,208,800 $13,768,603,500 $40,587,468,800

Economic imPacT $42,281,666,900 $24,527,578,500 $45,858,287,600 $112,667,533,000

nAtionAl econoMic iMPAct 41

6) John Dunham and Associates, New York, July 2009.

7) Schrank, David and Tim Lomax, Mobility Benefits from Motorcoach Service, Texas Transportation Institute, December 2009.

8) op cit, John Dunham and Associates.

n Motorcoach travel also alleviates con-gestion on local roads, city streets, and major arteries by removing cars from travel lanes; adds productivity to the workforce, and reduces pavement wear. In the United States, motorcoach travel saves 44 million gallons of fuel, 63 mil-lion hours of wasted time and $1.2 billion annually.7

n Motorcoaches bring millions of tourists who support local economies, and pro-vide efficient, flexible and cost effec-tive transportation, linking commuters to employment, and airports and rail stations to the surface transportation network. Motorcoaches provide the only form of public intercity transportation to millions of rural residents. This is all accomplished by an industry of small businesses with little to no taxpayer subsidies.

The United States Also Benefits from the Taxes Paid by the Industry

n Not only do the motorcoach travel and tourism industry create jobs, it also gener-ates substantial revenues for state and lo-cal governments. In the United States, the industry and its employees pay more than $7,498 million in taxes including property, income, and sales-based levies.8

taxes Generated in the United states

Tax Impact

FEdEral TaxEs $9,001,064,160

sTaTE TaxEs $7,498,049,137

ToTal TaxEs $16,499,113,297

42 FederAl sUBsidies

Introduction

The U.S. passenger transporta-tion infrastructure consists of airports, highways9, intercity rail10, and public transportation or mass transit systems. Federal

legislation during the second half of the 20th century spurred development of the infra-structure.

Airports | Federal government involve-ment in the development of private sector commercial air transportation can be traced back to the Air Mail Act of 1925, which au-thorized the postmaster general to contract for domestic airmail service with commer-cial air carriers. By doing so, the Federal government helped create the private sector commercial aviation industry11. However,

Federal support for airport development began in earnest in 1970 with passage of the Airport and Airway Development Act, which established the Airport Development Aid Program (ADAP) and the Airport and Air-way Trust Fund (AATF)12. AATF provides Federal funding for development of the U.S. aviation system through aviation-related ex-cise taxes, including airline passenger ticket taxes, head taxes on international passenger arrivals and departures, aviation fuel taxes, and air freight taxes.

Highways | The Federal-Aid Highway Act of 1956 created the interstate highway sys-tem, the largest public works program in U.S. history13. The Act authorized $25 billion for fiscal years 1957 through 1969 for the con-struction of 41,000 miles of highway14. The Highway Revenue Act of 1956 created

federal Subsidies for passenger transportation, 1960-2009

Robert Damuth: Economist and Principal Consultant, Nathan Associates Inc., March 2, 2011

9) Bus terminals are considered part of the highway transportation infrastructure.10) Rail stations are considered part of the intercity rail transportation infrastructure.11) “Airmail: The Airmail Act of 1925 through 1929,” U.S. Centennial of Flight Commission, July 2009, available at www.centennialofflight.gov/

essay/Government_Role/1925-29_airmail/POL5.htm. 12) Airport System Development, Office of Technology Assessment, U.S. Congress, Washington, DC, OTA-STI-231, August 1984, available at www.

princeton.edu/~ota/disk3/1984/8403/8403.PDF. 13) Wendell Cox and Jean Love, “The Best Investment a Nation Every Made, A Tribute to the Dwight D. Eisenhower System of Interstate and

Defense Highways,” American Highway Users Alliance, June 1996, available at www.publicpurpose.com/freeway1.htm. 14) Richard F. Weingroff, “Federal-Aid Highway Act of 1956: Creating the Interstate System,” Federal Highway

Administration, U.S. Department of Transportation, 1996, available at www.fhwa.dot.gov/infrastructure/rw96e.cfm. 15) “Primer: Highway Trust Fund,” Office of Policy Development, Federal Highway Administration, U.S. Department of Transportation, November

1998, available at www.fhwa.dot.gov/policy/primer98.pdf. 16) See “A Brief History of Amtrak,” Congressional Budget Office, September 2003, available at www.cbo.gov/doc.cfm?index=4571&type=0&sequ

ence=3. 17) See “Urban Mass Transit in the United States” by Zachary M. Schrag, Columbia University, available from the Economic History Association

at http://eh.net/encyclopedia/article/schrag.mass.transit.us. 18) “A Chronology of Dates Significant in the Background, History and Development of the Department of Transportation,” Office of the Historian,

U.S. Department of Transportation, available at http://dotlibrary.dot.gov/Historian/chronology.htm. 19) Ibid.

FederAl sUBsidies 43

the Highway Trust Fund (HTF) to be the source of funding for the program. Prior to the HTF, the general fund of the U.S. Treasury was the source of federal funding for highway construction.15 Proceeds from motor fuel and vehicle taxes were credited to the general fund. There was no direct relationship between these tax revenues and Federal funding of highway construction. With creation of the HTF, highway-user taxes, including excise taxes on highway mo-tor fuel and truck related taxes on truck tires, sales of trucks and trailers, and heavy vehicle use, were credited to the HTF and used to finance the interstate highway program.

Intercity Rail | The National Railroad Passenger Corporation (Amtrak) was cre-ated by Congress in the Rail Passenger Services Act of 1970 as a for-profit govern-ment owned corporation to provide intercity passenger train service. Private railroad provision of passenger transportation service had become unprofitable as a result of competition from the interstate highway system as well as commercial air carriers. Amtrak began operations in 1972 with $40 million in direct federal aid and $100 mil-lion in federally insured loans.16 Although Amtrak was originally envisioned to become self-sustaining, direct Federal aid continues to be required and provided.

Public Transportation or Mass Transit | The Urban Mass Transpor-tation Act of 1964 authorized $375 million in aid to the capital costs of transit projects.17 The Urban Mass Transportation Assistance Act of 1970 provided $10 billion over 12 years to upgrade mass transit systems.18 The National Mass Transportation Assistance Act of 1974 authorized $11.9 billion over a six-year span for capital and operating expenses of the nation’s mass transit systems.19 The Act of 1974 was the first time federal funds were authorized for mass transit operating costs as well as capital costs.

In this report, the study analyzed Federal government outlays on transportation and

AATF ................airport and airway trust fund

ACE ....................army corps of Engineers

ADAP ............... airport Development aid program

ARRA ............... american recovery and reinvestment act of 2009

BIA......................Bureau of indian affairs

BLM ....................Bureau of land management

BR .......................Bureau of reclamation

BTS ..................... Bureau of transportation Statistics

CAB ....................civil aeronautics Board

DHS .................... Department of homeland Security

DOA ...................Department of agriculture

DOD ...................Department of Defense

DOI .....................Department of the interior

DOT ....................Department of transportation

FAA ....................federal aviation administration

FEMA ................. federal Emergency management agency

FHWA ...............federal highway administration

FMCSA .............. federal motor carrier Safety administration

FRA ....................federal railroad administration

FTA .....................federal transit administration

HTF ...................highway trust fund

HUD .................... Department of housing and urban Development

MMS ...................mineral management Services

NASA ................. national aeronautics and Space administration

NCIP................... northeast corridor improvement program

NHWTSA ......... national highway traffic Safety administration

NPS ....................national park Service

NRPC ................. national railroad passenger corporation

OS .......................office of the Secretary

RRIP ................... railroad rehabilitation and improvement program

SAFETEA-LU .... Safe, accountable, flexible, Efficient transportation Equity act: a legacy for users

USFS ..................united States forest Service

UTP.....................urban transportation program

WMATA ........... washington metropolitan area transit authority

Glossary


present estimates of Federal subsidies that take into account Federal revenues raised from aviation- and highway-related excise taxes. The modes included in this analysis are U.S. private sector commercial airlines, au-tomobiles, private sector commercial buses, Amtrak, and mass transit, including transit buses, commuter rail, ferryboats, heavy rail, light rail, paratransit20, and vanpools.

The study defines a subsidy to be the dif-ference between Federal outlays on each system (airports, highways, intercity rail, and mass transit) allocated, when neces-sary, to specific modes and Federal excise tax revenues collected from system users.21 For example, if Federal government out-lays on airports and related services totaled

$100 million and aviation-related excise tax revenue totaled $90 million, the avia-tion industry would have received a Federal subsidy of $10 million.

It is important to note that the definition of a subsidy does not take into account all economic and social costs of the use of a par-

ticular mode of transportation. More specifi-cally, the study does not attempt to account for externalities, such as environmental or congestion costs of using one mode of trans-portation versus another. The study considers only Federal outlays and Federal excise tax revenues.

This study comes at an important time. The existing authorization for Federal surface transportation programs expired on September 30, 2009. Enacted on August 10, 2005, the SAFETEA-LU, has survived via continuing resolutions. Surface transporta-tion funding and spending authority were extended through December 31, 2010 at levels set in the fiscal 2010 Transportation Appropriations Act.

This study reminds policy-makers of inequities found in Federal support for passenger transportation that have effects on industry development and growth. Just as the Airmail Act of 1925 promoted the private aviation industry at the expense of railroads, uneven Federal support creates advantage for some industries and disadvan-tage for others.

This is not the first subsidy study. The initial study was released in 1989.22 Until then, no one had provided subsidy estimates for all modes in a single study at the level of detail provided by the study. Since then, the estimates have been updated, beginning with a July

1995 report, then an April 2003 report, and, most recently, a September 20, 2007 report. Along the way, the Bureau of Transporta-tion Statistics (BTS) of the DOT released a December 2004 report “Federal Subsidies to Passenger Transportation.”23 The BTS study was similar to those Nathan Associ-

FIG

UR

E 1

subsidies per Passenger trip, 1960-2001 and 2002-2009 (constant 2009 $)

1960-2001 2002-2009

n Private sector Commercial Air Passenger Carriers n Automobilesn Private sector Commercial Buses n Amtrak n Mass transit

Automobilesn/a

$7.75

$77.54

$57.04

$6.35

$.10 $.95$.61$.09Automobiles

n/a

20) Includes providers of service for the elderly and persons with disabilities.21) With respect to public transportation and Amtrak, the subsidy is simply Federal outlays on each system. 22) “Federal Subsidies for Passenger Transportation, 1960-1988: Winners, Losers, and Implications for the Future,” Robert R. Nathan Associates,

Inc., Washington, DC, May 1989.23) Available at www.bts.gov/programs/federal_subsidies_to_passenger_transportation/pdf/entire.pdf.


Federal subsidies by Mode, 1960-2009 and selected sub-periods

Mode 1960-2001 2002-2009 1960-2009

1) Private Sector Commercial Air Passenger Carriers

ToTal subsidy (2009 $ MILLIon) 101,715 36,097 137,812

sharE oF grand ToTal subsidy (a) 28.55% 28.69% 28.66%

avEragE annual subsidy (2009 $ MILLIon) 2,422 4,512 2,756

subsidy PEr PassEngEr TriP (2009 $) 7.75 6.35 7.33

subsidy PEr PassEngEr milE (2009 $) .01047 .00809 .00972

2) Automobiles

ToTal subsidy (2009 $ MILLIon) -4,897 1,231 -3,666

sharE oF grand ToTal subsidy (a) / 0.98% /

avEragE annual subsidy (2009 $ MILLIon) -117 154 -73

subsidy PEr PassEngEr TriP (2009 $) n/a n/a n/a

subsidy PEr PassEngEr milE (2009 $) -.00006 .00006 -.00004

3) Private Sector Commercial Buses

ToTal subsidy (2009 $ MILLIon) 1,491 502 1,993

sharE oF grand ToTal subsidy (a) .42% .40% .41%

avEragE annual subsidy (2009 $ MILLIon) 35 63 40

subsidy PEr PassEngEr TriP (2009 $) .09 .10 .09

subsidy PEr PassEngEr milE (2009 $) -.00086 (b) .00050 .00042

4) Intercity Rail

ToTal subsidy (2009 $ MILLIon) 48,826 (c) 11,663 60,489 (h)

sharE oF grand ToTal subsidy (a) 13.70% 9.27% 12.58%


subsidy PEr PassEngEr TriP (2009 $) 77.54 (d) 57.04 71.24

subsidy PEr PassEngEr milE (2009 $) .35495 (E) .25364 .31901

5) Mass Transit

ToTal subsidy (2009 $ MILLIon) 204,243 (F) 76,316 280,558 (i)

sharE oF grand ToTal subsidy (a) 57.33 60.66 58.35


subsidy PEr PassEngEr TriP (2009 $) .61 (F) .95 .68

subsidy PEr PassEngEr milE (2009 $) .18103 (g) .19264 .18459

Note: n/a indicates passenger trip data are not available for automobiles.(A) Grand total excludes any mode for which the cumulative subsidy over years was negative (B) 1985-2001 (C) 1971-2001 (D) 1980-2001 (E) 1975-2001(F) 1961-2001 (G) 1980-2001 (H) 1971-2009 (I) 1961-2009

so

urc

e: n

ath

an

Asso

cia

tes In

c.

TABLE 1


ates had been producing since 1989. More important, the BTS study found subsidy disparities similar to those Nathan Associ-ates had been estimating and documenting since 1989.

Our past studies have all reached a com-mon conclusion: the private sector com-mercial bus industry has been disadvan-taged by inequities in the distribution of Federal subsidies. Regardless of how the subsidy is expressed—total amount, amount per passenger trip, or amount per passenger mile—the bus subsidy is a minute fraction of the subsidy received by each of the other

passenger transportation modes. In abso-lute terms and relative to other commercial modes of passenger transportation, the private sector commercial bus industry pays its fair share of the Federal cost of highways and related services.

Results

Little has changed since release of the first subsidy study. From 2002-2009, private sector commercial air passenger carriers, Amtrak, and mass transit combined received

98.6 percent of the total federal subsidy. Automobiles and private sector commercial buses each received less than one percent (see Table 1 for a summary of estimated sub-sidies).

From 2002-2009, subsidies per passenger trip were significantly different across modes, with Amtrak and private sector commercial air passengers receiving subsidies as much as 400 times greater than passengers of less subsidized modes (Figure 1).

n Amtrak passengers received $57.04 per trip.n Private sector commercial air passengers

received $6.35 per trip.n Mass transit riders received

$.95 per trip.n Private sector commercial bus

passengers received $.10 per trip.

When considering subsidies per passenger mile, again Amtrak received most. However, because of the relatively short distances trav-eled by mass transit riders, on a per passenger mile basis, mass transit is the second most highly subsi-dized mode (Figure 2).

n Amtrak received a subsidy of $.254 per passenger mile.

n Mass transit received a subsidy of $.193 per passenger mile.

n Private sector commercial air passenger carriers received a subsidy of $.008 per passenger mile.

n Private sector commercial buses received a subsidy of less than $.001 per passenger mile.

The effects of 9/11 and the recession of 2008 are apparent in subsidy differences across the two sub-periods of our analysis (1960-2001 and 2002-2009) (Figure 3).

The average annual subsidy measured in constant 2009 dollars increased for each mode. For private sector commercial air passenger carriers, the average annual subsidy nearly doubled. For automobiles, a mode that has historically received little if any subsidy, the average annual subsidy

FIG

UR

E 2

subsidies per Passenger Mile, 1960-2001 and 2002-2009 (constant 2009 $)

1960-2001 2002-2009

n Private sector Commercial Air Passenger Carriers n Automobilesn Private sector Commercial Buses n Amtrak n Mass transit

$.0009 $.0005-$.0001 $.0001$.0105

$.3550

$.1810

$.0081

$.2536

$.1926


FIG

UR

E 3

Average Annual subsidy by Mode, Fiscal 1960-2001 and Fiscal 2002-2009 (constant 2009 $)

subsidy by Mode, Fiscal 2009 ($ million)

1960-2001 2002-2009

n Private sector Commercial Air passenger Carriers n Automobilen Private sector Commercial Buses n Amtrak n Mass transit

2,422

1,163

5,044

1,458

4,512

63154

9,539

4,853

35

-117

FIG

UR

E 4

3,542

83

1,787

11,336

24) According to the American Bus Association, the industry consumes approximately 331 million gallons of diesel fuel in a year. See “Motorcoach Census 2008: A Benchmarking Study of the Size and Activity of the Motorcoach Industry in the United States and Canada in 2007,” Table 2-5, p. 10, available at www.buses.org/files/Motorcoach%20Census%202008%2012-18-2008.pdf.

reached $154 million in 2002-2009, an ef-fect reflective of ARRA funding. Similarly, ARRA and safety and security concerns resulted in a doubling of the private sector commercial bus subsidy, although the mode remains virtually unsubsidized.

In 2009, the private sector commercial bus industry—the least subsidized mode—received a subsidy of $83 million, 3.75 percent more than the previous year’s subsi-dy (Figure 4). The subsidy was less than half of one percent of subsidies to other modes.

The private sector commercial bus indus-try subsidy is nearly fully accounted for by its partial exemption from the diesel fuel tax. Even with the exemption, when taking into account the Federal costs buses impose on highways and related services and the excise tax revenues paid by the industry, the industry receives virtually no subsidy. Unlike the other modes of passenger trans-portation, bus industry tax revenue nearly offsets total Federal outlays on behalf of the industry.

Without the partial exemp-tion, which is worth 17 cents per gallon of diesel fuel purchased by the industry, private sector commercial bus service would have contributed an additional $56.3 million to the HTF in 2009.24 This addi-tional amount would have cut the industry’s already negligible subsidy of $83 million in 2009 by two-thirds.

Considering the private sector commercial air passenger industry’s subsidy of $5 billion, Amtrak’s subsidy of $1.8 billion, and mass transit’s subsidy of $11.3 billion in 2009, loss of the partial exemption would have insig-nificant effect on Federal outlays, but signifi-cant effect on the private sector commercial bus industry.

48 enerGy Use & co2 eMissions

Introduction

This analysis is intended to eval-uate the environmental perfor-mance of Highway Motorcoach operations, by comparing the energy use and carbon dioxide

(CO2) emissions of motorcoaches with the en-ergy use and CO2 emissions of other common transportation vehicles/modes.

Including motorcoaches, a total of 12 transportation modes are included in the analysis, as follows:

Highway Motorcoach | According to the ABA vehicles in the motorcoach fleet are designed for long-distance travel, and are characterized by “integral construction with an elevated passenger deck located over a baggage compartment.” For this analysis the motorcoach mode includes motorcoach bus-es used for private charters, tours/sightsee-ing, scheduled inter-city service, and airport and commuter service between a central city and adjacent suburbs/airports.

Private Automobile | for this analysis the private automobile mode includes all use of a personally owned car or light truck for com-muting and other travel.

Heavy Urban Rail | A transit mode that uses self-propelled electric-powered passen-

ger cars operating on an exclusive rail right of way, either below or above-ground, to provide scheduled service within an urban area. Typi-cally the system is designed to accommodate very high passenger volumes, and trains are operated in multi-car sets. The electricity to power the vehicles is drawn either from over-head wires or from a power rail.

Light Rail | A transit mode that uses self-propelled electric-powered passenger cars operating on an exclusive or shared above-ground rail right-of-way to provide sched-uled service within an urban area. Typically the system is designed to accommodate lower passenger volumes than heavy rail, and passenger cars are operated singly or in two-car sets. The electricity to power the vehicles is drawn from overhead wires.

updated comparison of Energy use & co2 Emissions from Different transportation modes

M.J. Bradley & Associates LLC, October 2008

enerGy Use & co2 eMissions 49

Communter Rail | A transit mode that uses electric or diesel-powered locomotives pulling passenger cars, and operating on an exclusive rail right-of-way, for local short-distance travel between a central city and adjacent suburbs.

Intercity Rail | A transit mode that uses electric or diesel-powered locomotives pulling passenger cars, and operating on an exclusive rail right-of-way, for long-distance travel between cities.

Domestic Air Travel | Scheduled plane service operating between U.S. cities. For this analysis international air travel is not included.

Urban Transit Bus | A transit mode that includes the use of primarily diesel-powered, rubber-tired vehicles for fixed route sched-uled service within an urban area, and usu-ally operated in mixed traffic on city streets. The buses used for this mode are typically between 20-40 feet in length.

Electric Trolley Bus | A transit mode that uses electric-powered rubber-tired vehicles for fixed route scheduled service within an urban area, and usually operated in mixed traffic on city streets. Electricity to power the vehicles is drawn from overhead wires installed along the route.

Ferry Boat | A transit mode that uses marine vessels to carry passengers and/or vehicles over a body of water. Intercity ferryboat service is excluded, except for that portion of such service that is operated by or under contract with a public transit agency for predominantly commuter services.

Van Pool | A transit mode that uses vans, small buses, and other vehicles, operating as a ride-sharing arrangement, to provide

transportation to a group of individuals traveling directly between their homes and a regular destination within the same geographical area. For this analysis only vanpools operated by a public entity are included.

Demand Response | Shared-use transit service operating in response to calls from passengers to a transit operator, who sched-ules a vehicle to pick up the passengers to transport them to their destinations. This analysis only includes demand response service operated by public transit agencies, primarily to provide paratransit service to individuals with disabilities that preclude them from using fixed-route transit bus ser-vice. For this analysis the demand response mode does not encompass private taxis or private shared-ride van services.

This report is an update to a similar report issued in May 2007. This report uses updated 2006 and 2007 data not available for the previous report, but the results are similar to those reported in 2007.

For all modes both energy use and CO2 emissions are expressed in terms of units per passenger mile operated. The metrics used for energy intensity are passenger miles per diesel-equivalent gallon25 (pass-mi/DEG) and BTU26 per passenger mile (BTU/pass-mi). The metrics used for CO2 emissions are grams of CO2 per passenger mile (g/pass-mi).

Carbon dioxide is a greenhouse gas that has been linked to climate change. The most significant source of U.S. CO2 emissions is the burning of fossil fuels such as coal, gaso-line, diesel fuel, and natural gas for electric-ity production, space heating, industrial processes, and transportation. The trans-portation sector is a significant contributor to total man-made CO2 emissions.

All of the data used for this analysis is

25) This analysis compares modes that use different types of fuel, including diesel fuel, gasoline, and electricity. Energy use for all modes has been expressed in terms of a “diesel equivalent gallon” based on energy content. In this analysis one diesel equivalent gallon is defined as 138,000 BTU, the energy content of a gallon of “typical” highway diesel fuel. One gallon of typical highway gasoline contains 114,000 BTU, or .826 diesel equivalent gallons. One-kilowatt hour of electricity is equal to 3,412 BTU, so there are 40.45 KWH of electricity in one diesel equivalent gallon.

26) A British Thermal Unit (BTU) is a measure of energy. One BTU is equivalent to .000293 KWH.

publicly available. As discussed below the major sources of data include the Federal Transit Administration’s National Transit Database27; the Department of Transporta-tion, Bureau of Transportation Statistics, National Transportation Statistics; and a Coach Industry Census conducted by Nathan Associates for the ABA. For most modes the data is from calendar year 2006, the most recent year available. The Coach Industry Census covered calendar year 2007.

Results of Analysis

Average energy use and CO2 emissions by mode are shown in Table 1. Selected data from Table 1 is also summarized in Figures 1–3.

In Table 1 the high and low figures for mo-torcoaches are based on averages for differ-ent industry segments (charter/tour/sight-seeing versus commuter/airport/intercity fixed route service). For the other public modes the high and low figures are based on

the range of results from indi-vidual transit agencies in the NTD database. For private au-tos the averages are based on US fleet average fuel economy (22.4 MPG) while the high figures are based on the use of a “typical” sport utility vehicle (15 MPG) and the low figures are based on use of a hybrid car (46 MPG).

As shown, motorcoaches on average used 668 BTU/pass-mi and produced 50 g/pass-mi of carbon dioxide. On average, mo-torcoaches use the least amount of energy and produce the low-est carbon dioxide emissions per passenger mile of any of the transportation modes analyzed.

The most energy- and carbon dioxide-intensive mode is De-mand Response at an average of 15,727 BTU/pass-mi and 1,145 g CO2/pass-mi. Van Pools on average produce almost twice as much carbon dioxide per pas-senger mile as motorcoaches, commuter rail produces more than three times as much, two-person car pools produce almost four times as much, and single commuters produce more


FIG

UR

E 1

Passenger Miles Per Gallon of Fuel*

Motorcoach

Van Pool

heavy rail

Commuter rail

Intercity rail

Car Pool (2

person)

Light rail

trolley Bus

Domestic A

ir travel

Car (Avg. t

rip)

transit Bus

Car (1 P

erson)

Ferry Boat

Demand response

Motorcoach

Van Pool

heavy rail

Commuter rail

Intercity rail

Car Pool (2

person)

Light rail

trolley Bus

Domestic A

ir travel

Car (Avg. t

rip)

transit Bus

Car (1 P

erson)

Ferry Boat

Demand response

Motorcoach

Van Pool

heavy rail

Commuter rail

Intercity rail

Car Pool (2

person)

Light rail

trolley Bus

Domestic A

ir travel

Car (Avg. t

rip)

transit Bus

Car (1 P

erson)

Ferry Boat

Demand response

FIG

UR

E 2

Average energy Use (BtU) Per Passenger Mile

FIG

UR

E 3

Average carbon dioxide emissions (grams) Per Passenger Mile

250

200

150

100

50

0

1,400

1,200

1,000

800

600

400

200

0

18,00016,00014,00012,00010,000

8,0006,0004,0002,000

0

*Passenger mile per diesel-equivalent gallon

27) The modes included in this analysis for which data is included in the NTD are: Commuter Rail, Demand Response, Electric Trolley Bus, Ferry Boat, Heavy Urban Rail, Light Rail, Urban Transit Bus, and Van Pool.

enerGy Use & co2 eMissions 51

average fuel economy. Average energy Use and co2 emissions by Mode

ModePAssenGer Mile/

GAllon*BtU/PAssenGer Mile

co2 GrA./

PAssenGer Mile

Low Avg. High Low Avg. High Low Avg. High

moTorcoach 173.2 206.6 232.7 593 668 797 44 50 59

van Pool 60.3 106.1 203.8 677 1,300 2,289 50 97 170

hEavy rail 52 160.8 210.9 654 858 2,653 115 151 467

commuTEr rail 60.6 92.4 263.6 524 1,493 2,278 92 164 242

inTErciTy rail (AMtrAK)

55.8 67 128.1 1,077 2,061 2,471 190 186 184

car Pool (2 Person)

36.3 54.3 111.4 1,239 2,540 3,800 92 189 283

lighT rail 4 120.6 198.9 694 1,144 34,375 122 201 2,559

TrollEy bus 55.1 106.6 125.2 1,103 1,294 2,505 194 228 441

domEsTic air TravEl 44 3,138 234

car (AVg. trIP) 28.7 42.9 88 1,569 3,215 4,810 117 239 358

TransiT bus 4.4 31.4 124.1 1,112 4,391 31,296 83 308 2,330

car (1 Person) 18.2 27.2 55.7 2,478 5,080 7,600 184 378 566

FErry boaT 1.9 12.9 30.9 4,463 10,690 71,889 332 796 5,352

dEmand rEsPonsE 1.1 8.8 48.3 2,858 15,727 127,179 213 1,145 9,463

TABLE 1

*Passenger miles per diesel-equivalent gallon


than seven times as much.Note that the calculation of passenger miles

per gallon of fuel and BTU/pass-mi for elec-tric modes (heavy rail, light rail, trolley bus) is based on kilowatt-hours of delivered electric-ity and therefore does not account for the total fuel energy used to generate the electric-ity. Comparison of these metrics for electric modes to gasoline and diesel modes is there-fore somewhat misleading. The metric CO2/pass-mi does account for all carbon dioxide produced by electricity generation and there-fore provides a more relevant comparison between electric and diesel/gasoline modes.

Figures 4 and 5 show the range of en-

ergy use and CO2 emissions from selected modes. As shown, while some modes have favorable energy use and carbon dioxide emissions on average, there can be signifi-cant variation from location to location. For example, of 33 agencies in the NTD database that operate van pools the worst performer produced over three times as much CO2 per passenger mile as the best performer, primarily based on lower aver-age passenger loads.

Likewise, actual emissions per passenger mile from shared rides and car pools are highly dependent on the vehicle used, with lower emissions from cars that have better

FIG

UR

E 5

carbon dioxide emissions (grams) Per Passenger Mile

Motorcoach Van Pool Commuter rail Car Pool

300

250

200

150

100

50

0

FIXED ROUTEAVG.

CHARTER

WORST

AVG.

BEST

WORST

AVG.

BEST

LARGE SUV=15 MPG

PRIUS HYBRID

=46 MPG

U.S. AVG. FLEET FUEL

ECONOMY=22 MPG

Of 7 U.S.Transit

Agencies

Of 33 U.S.Transit

AgenciesTransit

Agencies

Of 7 U.S.Transit

Agencies

FIG

UR

E 4

energy Use (BtU) Per Passenger Mile

Motorcoach Van Pool Commuter rail Car Pool

4,000

3,500

3,000

2,500

2,000

1,500

1,000

500

0

FIXED ROUTEAVG.

CHARTER

WORST

AVG.

BEST

WORST

AVG.

BEST

LARGE SUV=15 MPG

PRIUS HYBRID

=46 MPG

U.S. AVG. FLEET FUEL

ECONOMY=22 MPG

Of 7 U.S.Transit

Agencies

Of 33 U.S.Transit

Agencies

Of 33 U.S.Transit

AgenciesAgenciesTransit

AgenciesAgencies

Note: Btu/passenger-mile for Commuter Rail does not account for effi ciency of electricty production

The American Bus Association is the trade association of the motorcoach, tour and travel industry, representing 1,000 motorcoach and tour operators in the United States and Canada. Its members operate charter, tour, regular route, commuter,

airport express and contract services. Another 2,800 member organizations represent the travel and tourism industry and suppliers of bus products and

services that work in partnership with the North American motorcoach industry.

111 K Street, NE 9th Floor, Washington, DC 20002-8110Phone: (202) 842-1645 • Toll Free: (800) 283-2877 • Fax: (202) 842-0850 • [email protected] • www.buses.org

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