Modern over the road buses are designed to have the climate control and air circulation systems
running whenever the bus is occupied, or will soon be occupied by, drivers or passengers.
- The temperature within the interior passenger compartment is highly variable, given the large number of windows, the lack of insulation, and the metal superstructure of the bus.
- The windows don’t open on the over-the-road buses. There is no way to regulate the temperature or circulate air on the buses if the HVAC system is not engaged, and there is no way to engage the HVAC system unless the engine is running.
- The passenger compartment of the bus is large, and it requires a significant amount of time to bring the bus to a 68-75° range, which can necessitate idling before passengers board the bus.
- The industry uses the same Prevost and MCI buses as MTA Bus Company and MTA MABSTOA uses to provide express bus service for residents of Brooklyn, the Bronx, Queens and Staten Island; in other services same New Flyer and others used by MTA NYC Transit. Those buses are serve the same riding public.
- NYC BUS LANES are utilized by ALL Buses, Public and Private for Public Transport. The climate control and air circulation systems are necessary to preserve passenger comfort and safety, and to comply with federal rules and standards.
- FMCSA rule 49 CFR § 374.313(a) requires over-the-road buses to be maintained at a “reasonable temperature.” OSHA recommends workplaces to maintain a temperature between 68 and 76 degrees. (see, OSHA Technical Manual Section III(2)(V)). On especially hot or cold days, it is not possible to comply with these rules and recommendations without idling the vehicle.
- Our fleets often serve seniors and children. Generally, seniors and children are biologically less able to regulate their internal temperatures and are therefore more susceptible to chills, dehydration or heat exhaustion. We must take special care to provide for those passengers’ health and safety.
- In addition, the air circulation system reduces the risk of airborne transmission of pathogens, which is especially important for people with compromised immune systems, especially children and seniors. Auxiliary Power Units are not feasible for over the road applications in New York City.
- We have searched for, and been unable to find, any available Auxiliary Power Unit (APU) vendors which are powerful enough to power an over-the-road bus’ climate control and air circulation systems.
- The APU/HVAC solutions that we are aware of have been used by entertainment coach buses. Those solutions essentially mount heat pump units to the roof of the bus, with additional equipment in the luggage compartment. The roof mounted heat pump units add 12-18 inches of height to the bus. This added height would make over-the-road buses too tall to enter Manhattan via the Holland Tunnel, Queens Midtown Tunnel, Lincoln Tunnel, Brooklyn Battery Tunnel, and many bridges and key corridors across the City.
- We note that although the APUs on the entertainment coach buses would enable the climate control and air circulation systems to function while the engine is off, and thereby comply with the anti-idling law, the APU itself burns diesel, and produces emissions that are similar to a Tier 4 construction generator. Accordingly, we anticipate that, from an emissions perspective, the APUs that are available today would not actually appreciably reduce the amount of pollutants from the air.
- We continue to engage APU manufacturers in order to push them to develop new designs which add less height to the bus and enable our fleet to comply with vehicle height clearances. Electrification is not feasible for over-the-road service
- There are no electric over-the-road buses available for purchase. Unlike transit buses, which operate on short, predictable routes that facilitate frequent charging, over-the-road buses travel long and variable distances. Also, electric buses would likely weigh too much for NYC bridges.
- These factors explain why NYC Transit has only electrified a tiny portion of their fleet, and hasn’t electrified any of the express buses which travel from the outer-boroughs to Manhattan. Improvements to the fleet to reduce engine idling
- We provide extensive training to bus operators to prevent idling. Our bus operators are trained to shut off the bus whenever possible, unless that idling is necessary to maintain a comfortable and safe climate on the bus. We inform bus operators that idling increases fuel costs and causes twice as much wear to engine parts as driving at regular speeds. We also inform bus operators of the dangers posed by emissions to public health, especially children and seniors. This training is provided to all newly hired bus operators, and periodically reinforced at staff meetings and through posters and other written materials.
- We use electronic logging devices to log idling and identify bus operators who need to be reminded of our priority to reduce unnecessary idling. Improvements to the fleet to reduce the impact of engine idling
- Our buses comply with all current federal and state emissions standards, including the latest EPA standards for Clean Diesel Technology.
- We have incorporated technologies in the bus to reduce emissions (e.g., diesel particulate filters).
- We have instituted an array of maintenance efforts, including but not limited to such as regular exhaust system inspections, frequent oil changes, the use of particular fuel blends and motor oils, etc, to reduce emissions and our motor coaches meet the latest EPA standards for Clean Diesel Technology.
- We also are founding members of the “NYC Bus Anti-Idling Best Practices Workgroup” where we share information about available technologies and practices that can be used to reduce the industry’s carbon footprint.