Summary of Key Findings

The comparative analysis between BOs and LTAs revealed several key considerations and potential strategies necessary for a successful, efficient, and equitable transition to ZEBs through the proposed measure.

The mixed reactions regarding preferred implementation timelines highlighted the need for a balanced approach. While LTAs generally favoured earlier implementation to meet local emission and climate targets, BOs preferred later dates due to operational concerns and the desire to maximise the residual value of their existing fleet. There was a clear consensus that 2030 is too early, and an emerging preference for 2035, suggesting that a phased timeline could provide the necessary flexibility to secure funding and allow for technological and infrastructure advancements.

Secondly, access to government funding emerged as a predominant theme. Both LTAs and BOs emphasised the need for substantial financial support to manage the high upfront costs associated with ZEBs and the necessary infrastructure. Smaller, rural, and long-distance operators face particular challenges in this regard. Smaller operators struggle financially due to a lack of capital, which impacts their ability to invest in new vehicles and infrastructure. Rural operators face unique challenges, such as prohibitively high costs for charging infrastructure due to geographical factors, which could jeopardize their operations. Whilst long-distance coaches face logistical challenges with the range of ZEBs and the need for charging infrastructure along routes. These complexities call for targeted policies and funding models to ensure these ‘vulnerable’ operators are not disproportionately impacted.

Thirdly, the disparity in current fleet composition and depot infrastructure between LTAs and BOs points to the necessity of tailored strategies. LTAs lag with ZEB adoption and have limited charging infrastructure compared to BOs, who are more advanced in their electrification efforts in terms of fleet, depots and decarbonisation plans. Consequently, the regulatory approach must consider these differences, providing specific support to LTAs to bridge the gap and encourage BOs to continue their progress.

Moreover, the barriers to decarbonisation identified in the surveys—cost, shortage of skilled personnel, limitations of current ZEB technologies, and infrastructure constraints—underscore the need for consideration of the bigger picture. Accelerating decarbonisation timelines will require not only funding but efficient financing models, enhanced product availability, and national commitment to expanding grid capacity. Clear guidance from the Government will be crucial in navigating these complexities.

Given the varied adaptability and local context of different operators and authorities, a phased approach with stepped timescales and tailored funding models could facilitate a smoother transition. Additionally, the Government could explore the role of other technologies such as HVO-fuels or hydrogen in tandem with ZEBs, during the phased transition. This would reduce emissions whilst mitigating hard constraints such as lack of grid capacity, which is reportedly a particularly hard constraint for rural operators. The strategy should aim to mitigate the additional imposed costs on disadvantaged operators and passengers, ensuring a fair regulatory approach that supports all stakeholders in achieving decarbonisation goals.