Road destroyers. The IRTE says given 12/13 ton loading, stop start operation and relatively high power to weight ratios, the failure to limit BRT vehicles with some regulation to keep them on the designed tracks will destroy what is left of South Africa’s potholed city road infrastructure.

The government is considering raising the legal axle mass limit on buses in the controversy stricken Bus Rapid Transit System (BRT) to 13 tons on a steering axle.

13 tons on a steering axle – this not a belated April fool joke- it is deadly serious and is just one of a series of proposals that government is considering to accommodate buses in the Bus Rapid Transit System (BRT). FleetWatch does not normally get involved in the bus industry, but we just had to take a closer look at this mess.  LAUNCHED AMID much fanfare and lauded as the panacea to South Africa’s blighted urban commuter transport system, the BRT that government is determined will be the principal mode of city and urban commuter transport during the 2010 Soccer World Cup and beyond has been embroiled in one controversy or another since it was first mooted.  With a lawless taxi industry (read mafia) threatening blood on the streets after first accepting and then violently opposing the BRT concept and now with a series of proposed regulatory amendments which, if promulgated, would make a mockery of the Road Traffic Act, it appears South African commuter transport is on a road to nowhere.  In addition to increasing the legal axle mass on BRT buses, government has proposed lifting the limits on the overall length of the buses and directing that doors be placed on the left and right hand side of the vehicles so they are able to drop passengers off in the middle of the road.  Asked to comment on the proposed amendments, the Road Freight Association, (RFA), and the technical committee Institute of Road Transport Engineers, (IRTE), describe some of the proposals as “totally unacceptable” and “unnecessary.”  Transport legislation authority and consultant / advisor to the DoT, Alta Swanepoel, notes that the proposed amendments to the Road Traffic regulations contains some mistakes and will not, in any event, be promulgated in their present format.  “I have commented to the DoT on these proposals concerning drafting mistakes, but not the principles included in the legislation,” she says. “As these vehicles are going to be run by Metro councils and they are also responsible for the road maintenance of their roads, I suppose they will make a decision between the costs for the transport system and the road maintenance.”  Totally unacceptable. The Road Freight Association and the technical committee of the Institute of Road Transport Engineers has denounced government proposals to increase axle mass limits on buses used in the BRT system.

Following we have highlighted a number of the proposed amendments as they appeared in Government Gazette Vol. 524 No.31953 February 2009 and the comments compiled by Gavin Kelly of the RFA and Jim Campbell of the IRTE. 

Regulation 221
Overall length of vehicle:

No person shall operate on a public road - (e) a bus train if the overall length thereof exceeds 22 metres;

Amendment of Regulation 221 of the Regulations

Regulation 221 of the regulations is amended by the addition after paragraph (e) - see above - of the following proviso clause: 

“Provided that in the case of a rapid transport bus-train, the limit on overall length shall not apply.” 

FW: Does this mean a BRT bus-train can be as long or as short as the operator desires? 

RFA /IRTE comment:

This is totally unacceptable. Whilst accepting that the intent is that these vehicles will supposedly operate within a dedicated BRT system, the definition of a BRT system includes public roads (see observation above). 

On the understanding that these vehicles may then operate on public roads, then the overall length must be within the current maximum of 22m for bus trains, and vehicle combinations, for reason of safety, manoeuvrability, and greatly increased overtaking distances by other vehicles.

Further, how are these buses to be transported from the port of entry to the point of operation, or to and from repair and servicing facilities when in service? Will they be transported under abnormal load restrictions? 

Regulation 240:
Massload carrying capacity of road

No person shall operate on a public road a motor vehicle or a combination of motor vehicles, the wheels of which are fitted with pneumatic tyres if – 

(c) the axle massload of an axle fitted with four wheels and – 

(iii) which is placed in the rear or middle of a bus-train, exceeds 10 200 kgs; 

(iv) which is fitted to a bus other than a bus-train, exceeds 10 200 kgs; 

(g) the axle massload of an axle unit which consists of three or more axles, each of which are fitted with four wheels, exceeds 24 000 kgs. 

Amendment to Regulation 240 of the Regulations

Regulation 240 is amended by

(a) the addition after item (iii) of paragraph (c) of the following proviso clause: “Provided that in the case of a rapid transport bus train that the limit on the driving axle shall be 13 000kg and on the other non-steering axle shall be 13 000 kgs.” 

(b) the addition after item (iv) of paragraph (c) of the following proviso clause: “provided that in the case of a rapid transport complementary bus, or a rapid transport trunk bus, this limit shall be 12 000 kgs.” 

(c) the substitution for paragraph (g) of the following paragraph: "(g) the axle massload of an axle unit which consists of two axles, one of which is a drive axle with four wheels and the other is an axle with two wheels, and which is fitted to a rapid transport bus, if the sum of the two axle mass loads exceeds 18 200 kgs.” 

(d) the addition after paragraph (g) of the following proviso clause: “Provided that the limitations on steering axles and steering axle units in paragraph (a), (b) and (f) above, do not apply to any axle or axle unit which assist in reducing the turning circle of a rapid transport bus or rapid transport bus-train, but which is not the front axle or front axle unit. 

RFA/IRTE comment:

Clause (a): The Dept of Transport has been claiming for many years that overloaded freight vehicle axles cause serious damage to roads, but the proposed 13 000 kg axle rating for BRT vehicles is 45% higher than the current limit for freight vehicles, and this is to be considered a legal permissible maximum load for BRT buses. 
Clause (b): As for item (a) above, and even though this permissible load is 33,3% higher than for freight vehicles, these buses will at all times be operating on public roads. 
Clause (c): A freight vehicle with a dual axle unit, with a mixture of dual and single tyres is limited to 15 400kg. The permissible mass for BRT related buses is 18 200kg or 18% higher than for a freight vehicle, again this an unacceptable difference. 
Clause (d): There is no indicated limitation on whether this proposed amendment will be reduced should any of the prescribed axles be fitted with single wheels, and again the proposed mass loads of 13 000kg are rejected. 

Regulation 242

Distribution of axle massload and wheel massload on vehicles fitted with pneumatic tyres 

(c) in the case of a motor vehicle not being a combination of motor vehicles as referred to in paragraph 
(b) with a steering axle unit, the sum of the axle massloads of such steering axle unit is less than 30% of the sum of all axle massloads of such vehicle. 

Amendment to Regulation 242 of the Regulations

Regulation 242 is amended by the addition of the following proviso clause after sub-paragraph (c): 

“Provided that in the case of a rapid transport bus-train no limit shall apply.” 

RFA/IRTE comment:

Not acceptable. A minimum mass load  must be determined and applied. This is for reasons of steering stability and subsequent road safety. 

Regulation 252

Entrances, exits and emergency exits of mini-buses and buses 

(i) no entrance for persons, other than the driver, shall be provided on the right hand side of the longitudinal centre line of a mini bus or bus operating for reward. 

Amendment to regulation 242 of the Regulations

Regulation 252 is amended by –

(a) the addition after paragraph (i) of sub-regulation (1) of the following proviso clause: “Provided that in the case of a rapid transport bus or a rapid transport bus-train which shall have exits on the right-hand side in addition to any on the lefthand side.” 

RFA/IRTE comment:

This together with the number and position of doors required later in the proposed changes to this regulation, indicate that passengers will access/exit the bus to a station located in the centre of the BRT rapid transport lane, or, if on a public road to load and discharge in the centre of the road. 

It also appears from these proposed amendments that the design of the buses are for left hand drive countries, and have not been, or will not be, modified for right hand drive configuration used in South Africa. There could be serious potential dangers for passengers in trying to gain access to pavements under either of the two above passenger transit situations. 

In addition to commenting on the actual amendments, Kelly provided FleetWatch with the following additional general comments and observations submitted by members of the IRTE technical committee. 

On the subject of increased mass limit on drive axles, the committee says drive axles are the road destroyers - given 12/13 ton loading, stop start operation and relatively high power to weight ratios, the failure to limit these vehicles with some regulation to keep them on the designed tracks will finally destroy what is left of South Africa’s potholed city road infrastructure. 

The technical committee says there needs to be an explanation as to why BRT buses need 13 000 kg maximum mass on the axles and questions if this is really necessary. 

The committee notes that the 27 metre double articulated pilot vehicle bus, constructed by MAN and Buscor for Mpumalanga, did not call for additional axle load, and operates at a 10 200kg permissible rear axle mass. 

“If this is accepted the next step is normal bus operators will be calling for higher axle masses on normal roads yet, Road Freight is restricted to only 9 000 kg,” says the committee. 

Adding to this the committee notes:  “The magnitude of the proposal is, then, an increase of 62% (over 8 000kg), which when multiplied by the non linear road damage factor becomes a horrendous number. 

“The drive axle, especially on the stopstart start work of bus operation, is the most punishing of axles, with drive torque further damaging the road. (An American research project quotes that 70-90 per cent of city street damage is caused by buses). 

“Given the high tare mass of passenger vehicles, (typically 66% and upwards of GVM, against a freight vehicles tare of, say 30% of GVM) it can be seen that a bus with a 13 ton axle unit is going to be above the ‘legal limit’ of freight vehicles, and thus in road damage mode, even when empty. 

“There would appear to be absolutely no technical reason, cost apart, requiring any axle above the 10,2 tons that was granted by default years ago - just fit a second axle. The proposed regulation appears to cater for this in any case with specific reference to a new 18,2 ton bogie limit (i.e.10.2 ton drive plus 8 ton single tyre tag axle.) 

Readers interested in reading the amendments in full should visit: 
http://www.info.gov.za/view/DownloadFileAction?id=96859