2016 04 Passenger Transport by Coach in Europe PDF
2016 04 Passenger Transport by Coach in Europe PDF
2016 04 Passenger Transport by Coach in Europe PDF
by Coach in Europe
by Coach in Europe
Steer Davies Gleave has prepared this material for DG MOVE, European Commission. This material may
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using information available to it at the time and as such any new information could alter the validity of
the results and conclusions made.
Comprehensive Study on Passenger Transport by Coach in Europe
Contents
Executive Summary....................................................................................................................... i
Introduction ................................................................................................................................... i
Our approach ................................................................................................................................. i
Operators ....................................................................................................................................... i
Fleets..............................................................................................................................................ii
Employment...................................................................................................................................ii
The domestic coach markets .........................................................................................................ii
The international coach market ...................................................................................................iii
Regulation 1073/2009’s impact on administrative burden ..........................................................iii
Regulation 1073/2009’s impact on travel markets ...................................................................... iv
Regulation 1073/2009’s categorisation of coach services ........................................................... iv
Regulation 1073/2009’s reporting and monitoring arrangements ...............................................v
Terminals .......................................................................................................................................v
Persons with reduced mobility ..................................................................................................... vi
International coach fares ............................................................................................................. vii
1 Introduction ....................................................................................................................... 9
Purpose and scope of this report ................................................................................................. 9
Organisation of this report ......................................................................................................... 12
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6 Terminals ......................................................................................................................... 90
Introduction ................................................................................................................................ 90
Terminals across the EU ............................................................................................................. 91
Terminal provision, control and regulation ................................................................................ 95
Terminals: ensuring access to existing capacity ......................................................................... 98
Terminals: adding or relocating capacity.................................................................................. 104
Terminals case study ................................................................................................................ 105
Key findings and conclusions .................................................................................................... 108
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8 Findings ..........................................................................................................................124
Introduction .............................................................................................................................. 124
The size of the domestic and international coach markets...................................................... 124
Regulation 1073/2009’s impact on administrative burden ...................................................... 125
Regulation 1073/2009’s impact on travel markets .................................................................. 132
Regulation 1073/2009’s categorisation of coach services ....................................................... 134
Regulation 1073/2009’s reporting and monitoring arrangements .......................................... 137
Access to terminals ................................................................................................................... 139
Persons with reduced mobility ................................................................................................. 139
The potential impacts of further liberalisation......................................................................... 140
Issues for further market integration ....................................................................................... 142
Future monitoring and information provision.......................................................................... 146
Figures
Figure 1.1: Stakeholders contacted and responding, July to November 2015 ........................... 11
Figure 3.1: EU and EU15 new vehicle registrations of buses and coaches over 3.5 tonnes ...... 21
Figure 3.2: EU and EU15 new vehicle registrations of buses and coaches over 16 tonnes ....... 22
Figure 3.3: UK big bus and coach registrations by quarter (2009-2015) .................................... 23
Figure 3.4: EU15 selected new vehicle registrations per inhabitant .......................................... 24
Figure 3.5: EU11 new vehicle registrations, buses and coaches under 3.5 tonnes (2004-2014)25
Figure 3.6: Spain: distribution of the bus fleet by registration year .......................................... 26
Figure 3.7: Estimates of coach sector employment ................................................................... 29
Figure 3.8: Estimates of coach sector employment trend (2008-2013) ..................................... 30
Figure 4.1: Domestic coach travel: mix of services in Lithuania (2009-2014) ............................ 41
Figure 4.2: Domestic coach travel: estimated average trip length............................................. 43
Figure 4.3: Domestic regular services: growth in reported passengers (2009-2014) ................ 44
Figure 4.4: Domestic occasional services: growth in reported passengers (2009-2014) ........... 44
Figure 4.5: Index of growth in average yield (2012-2014).......................................................... 47
Figure 4.6: Domestic regular services: fares for interurban coach journeys.............................. 49
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Figure 4.7: Cheapest fares for interurban coach and rail journeys under 300 kilometres ........ 50
Figure 5.1: International networks: Ecolines .............................................................................. 58
Figure 5.2: International networks: Lux Express ........................................................................ 60
Figure 5.3: International networks: PolskiBus ............................................................................ 61
Figure 5.4: Community licences (end 2010 to end 2014) ........................................................... 68
Figure 5.5: Community licences by Member State (end 2010 and end 2014) ........................... 69
Figure 5.6: Certified true copies (end 2010 to end 2014) .......................................................... 70
Figure 5.7: Certified true copies by Member State (end 2010 and end 2014) ........................... 71
Figure 5.8: Valid authorisations for regular international services (end 2014) .......................... 72
Figure 5.9: Authorisations: major imbalances by direction (end 2014) ..................................... 73
Figure 5.10: International coach travel: estimated average trip length..................................... 79
Figure 5.11: International regular services: growth in reported passengers (2009-2014) ........ 80
Figure 5.12: International occasional services: growth in reported passengers (2009-2014) ... 81
Figure 5.13: Estimates of international coach passenger growth (2009-2014) ......................... 82
Figure 5.14: Estimates of international coach passenger-kilometre growth (2009-2014)......... 82
Figure 5.15: Cheapest fares for international coach and rail journeys ...................................... 85
Figure 5.16: Cheapest fares for international coach and rail journeys ...................................... 85
Figure 6.1: United Kingdom: Heathrow Hoppa hotel services ................................................. 100
Figure 6.2: Sweden: bus terminal gate dedicated to an operator............................................ 101
Figure 6.3: United Kingdom: improvised London coach station after 1985 deregulation ....... 105
Figure 6.4: Example of an airport coach service to multiple suburban stops .......................... 110
Figure 7.1: PRMs: Designated Bus Terminals ........................................................................... 118
Figure 7.2: Disabled persons as a proportion of the population .............................................. 119
Figure 7.3: Disabled persons by Member State........................................................................ 119
Figure 7.4: PRMs: good practice on terminal information and routes ..................................... 122
Figure 8.1: Germany: authorised long-distance regular coach services (2012-2015) .............. 133
Tables
Table 2.1: Categories of coach services used in Regulation 1073/2009 .................................... 13
Table 2.2: Transport services provided by bus and coach .......................................................... 14
Table 3.1: Operators identified in the Member States............................................................... 16
Table 3.2: Operator fleet size estimates (2013) ......................................................................... 20
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Table 3.3: UK bus and coach registrations (2014 and 2015) ...................................................... 23
Table 3.4: Estimates of coach sector employment..................................................................... 28
Table 4.1: Domestic regulatory frameworks .............................................................................. 33
Table 4.2: Domestic coach routes .............................................................................................. 36
Table 4.3: Domestic passengers by year (thousands) ................................................................ 37
Table 4.4: Domestic passengers by market sector (thousands) ................................................. 39
Table 4.5: Domestic passenger-kilometres by year (million) ..................................................... 40
Table 4.6: Domestic passenger-kilometres by market sector (million) ...................................... 42
Table 4.7: Summary of indicative estimates of European coach market statistics .................... 46
Table 4.8: Domestic services: examples of change in average yield .......................................... 47
Table 4.9: Domestic services: sample of interurban coach journeys ......................................... 48
Table 4.10: Domestic services: barriers to entry by Member State ........................................... 51
Table 5.1: International coach services by Ecolines ................................................................... 59
Table 5.2: International coach destinations served by Lux Express ........................................... 59
Table 5.3: International coach services of Simple Express ......................................................... 60
Table 5.4: Categories of coach services used in Regulation 1073/2009 .................................... 65
Table 5.5: Community licences, authorisations and journey forms ........................................... 66
Table 5.6: Authorisations for cabotage by regular services (2014) ............................................ 75
Table 5.7: International coach routes identified by Member States.......................................... 76
Table 5.8: International coach passengers (2009-2014) ............................................................ 77
Table 5.9: International coach volumes (2009-2014) ................................................................. 78
Table 5.10: Cheapest fares for international coach and rail journeys........................................ 84
Table 6.1: Terminals: examples .................................................................................................. 91
Table 6.2: Terminals: examples of locations .............................................................................. 94
Table 6.3: Terminals: examples of ownership and regulation models ....................................... 96
Table 6.4: Terminals: approaches to managing access .............................................................. 98
Table 6.5: Terminals: example of operations at London Heathrow airport ............................. 106
Table 6.6: Terminals: barriers to entry ..................................................................................... 112
Table 6.7: Terminals: issues for consideration ......................................................................... 113
Table 7.1: PRMs: summary of European Disability Forum comments ..................................... 115
Table 7.2: PRMs: progress with equipment of coach fleets ..................................................... 116
Table 7.3: PRMs: provision by coach operators in France ........................................................ 116
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Table 8.1: Summary of indicative estimates of European coach market statistics .................. 124
Table 8.2: Barriers to effective market monitoring .................................................................. 138
Table 8.3: Terminals: barriers to entry ..................................................................................... 139
Table 8.4: Issues for further market integration ...................................................................... 142
Table 8.5: Possible objectives for “integration” in the coach industry .................................... 143
Appendices
E Glossary ..........................................................................................................................358
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Executive Summary
Introduction
On 4 December 2011, Regulation 1073/2009 came into force, replacing Council Regulation
(EEC) 684/92 and Council Regulation (EC) No 12/98 and providing a set of common rules for
access to the international market for coach and bus services. It was intended to clarify and
simplify rules, to improve enforcement, and to avoid unnecessary administrative burden.
Regulation 1073/2009 set out how:
carriers from all Member States should be guaranteed access to international transport
markets without discrimination on grounds of nationality or place of establishment;
regular services provided as part of a regular international service should be opened up to
non-resident carriers (“cabotage”);
authorisation could be refused if the service would seriously affect the viability of a
comparable service operated under one or more public service contracts (PSCs); and
administrative formalities should be reduced as far as possible.
In March 2015, the European Commission commissioned this study to provide a thorough
review and analysis of the European coach industry, including domestic long and medium
distance and international services.
Our approach
We examined international coach services, the subject of Regulation 1073/2009, and
developed case studies of the domestic coach industry in ten Member States and shorter
fiches on the remaining Member States, which are attached as Appendices A and B.
In July 2015 we contacted 159 stakeholders in the Member States and, by the end of
November 2015, had received 73 complete or partial responses, an overall response rate of
46%. We continued to contact and seek responses from stakeholders until April 2016, a few
days before this report was finalised. The report reflects all the stakeholder comments which
we have received.
Given the problems encountered in the past in the collection of detailed statistical transport
data, the collection of such data was excluded from the scope of the study. However, we have
sought to identify data on the market, coach fleets and employment across the European
Union from a number of sources.
Operators
Coach operators may provide both coach and bus services, and may combine reporting of
these operations in a given Member State with data on the operation other modes or
operations in other countries. This has the effect that their annual reports rarely identify the
size and performance of the coach part of the business.
Many coach brands are a marketing alliance or partnership, managed by one operator and
operated by several companies or by subcontractors. Many coach companies are domestic
subsidiaries of foreign owning groups, and the ultimate ownership of individual coach
operators may depend on mergers and acquisitions activity among a more limited number of
parent companies, including national rail operators such as Deutsche Bahn AG, ÖBB and SNCF,
and major transport groups such as Arriva, National Express, Stagecoach and Transdev.
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In some Member States, there is clear dominance in certain markets. National Express
emerged as a dominant operator shortly after liberalisation in the UK, and within two years of
German liberalisation, in January 2013, the two largest players merged to create a business
with over 50% market share.
Hence, while the sector is commercially focused and responsive to new market opportunities,
in particular opportunities arising from liberalisation, it is important to recognise the potential
for market dominance and distortion of competition. Constraints on competition can be a
particular feature of coach markets in which access to key infrastructure, notably coach
terminals, is restricted. We discuss the implications of constrained infrastructure throughout
our report and summarise them further below.
Fleets
The EU statistical pocketbook reports that the European bus and coach fleet amounted to
822,900 vehicles in 2013. We have been able to estimate the number of coaches in some
Member States but not in others.
Many transport statistics (and languages) do not distinguish between buses and coaches, and
no set of rules consistently applies to all Member States. For example, although in most EU-15
Member States standing passengers are not permitted on inter-urban bus/coach services, this
is not the case in all Member States. Similarly, vehicles with a separate luggage compartment
which might usually be considered ‘coaches’ are used on urban and rural bus services in some
Member States.
The European Automobile Manufacturers Association (ACEA) provides data on new bus and
coach registrations within the EU. We found no consistent evidence that liberalisation has led
to a growth in new vehicle registrations across the EU. However, there is evidence that
registrations increased in France, Italy and Sweden when Regulation 1073/2009 came into
force. Registrations fell in Germany after domestic liberalisation led to a major growth in
coach services, but this is consistent with a more effective deployment of a fleet that was
previously underutilised following recession.
Employment
Eurostat reports employment in “other land passenger transport n.e.c. (not elsewhere
classified)” including coach but also other minor modes. We estimated that employment in the
domestic and international coach industry is slowly declining and by 2014 was around 0.55
million, with a margin of error of ±10%. This decline may conceal a mixture of growing
volumes and increasing productivity. It is also consistent with our view that the sector has
remained relatively stable in the face of recession, and an indication of the responsiveness and
flexibility of commercially focused operators across the EU.
The domestic coach markets
The regulatory frameworks for domestic coach services vary widely between the Member
States. For example:
Some have created a number of regional concessions, either by direct award or
competitively, with exclusive rights to operate services.
Some permit commercial operations, subject to rules designed to protect PSO services.
Some permit commercial operations carrying passengers beyond a minimum distance.
Some delegate responsibility to regional, County or municipal authorities.
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The result is that the regulatory framework may vary not only between Member States but
also within Member States between regions, within regions between municipalities, and
within municipalities between coach terminals or even between bus stops. This patchwork of
regulatory frameworks may present a deterrent to prospective operators seeking to provide
services which straddle municipal, regional and national boundaries. This disproportionately
affects small and medium-sized enterprises (SMEs) which may not necessarily have the
resources needed to develop consistent business strategies throughout the EU.
Member States monitor domestic services to different extents. For example, better data are
available in Spain, which has regional concessions, than in other Member States with
liberalised markets. From the information available, we estimated that the volume of travel in
the domestic coach markets of the EU was 285 billion passenger-kilometres in 2014, with a
margin of error of ±25%. This is consistent with our estimates, in a 2009 report for the
Commission, of the volume of travel in 2008 (263 billion passenger-kilometres), and a
subsequent pattern of recession and slow recovery.
Over the period since 2012, there is evidence that average yields have been rising for
operators of public service contracts or concessions (such as ALSA in Spain) and falling for
those in competitive markets (such as Swebus in Sweden), although it is not possible draw firm
conclusions as we have estimates for only one company in each category. This tends to
support our view that operators have exploited opportunities to respond to market conditions
and to capture market share from other modes through price competition. Again, the
evidence from Spain, where passenger kilometres have fallen by an average of 4% per annum
since 2009, suggests that transport authorities specifying concessions have been slow to react
to the changing economic climate.
Even where markets are liberalised and in principle open, we identified a number of barriers
to entry including arrangements which favour an incumbent, and either restricted access to, or
limited capacity at, terminals.
The international coach market
The international coach market is small compared to the domestic markets but appears to be
growing. Few Member States produce separate statistics on international services, and the use
of inconsistent definitions limits the availability and reliability of the information produced.
Nevertheless, we estimate that international coach passenger numbers grew by 40-60%, and
international coach passenger-kilometres grew by 0-40%, between 2009 and 2014. Stronger
growth in international markets relative to the overall market suggests that operators have
responded to opportunities provided by international liberalisation although, as discussed
below, it is difficult to draw firm conclusions on the basis of the limited data available.
Regulation 1073/2009’s impact on administrative burden
Stakeholders did not explicitly attribute to Regulation 1073/2009 either a change in the cost of
oversight and compliance or a change in their number of employees. The workload of
operators and national competent authorities is likely to have been standardised and
streamlined, but none reported any quantified saving in administrative burden. Nonetheless,
we estimate that there may have been a net saving of staff across the European Union.
At the same time, the Regulation requires competent authorities requesting refusal of an
application to operate an international service to support their request with a detailed analysis
rather than a direct refusal. Competent authorities choosing to challenge applications, which
many do not (we have only identified evidence of applications being challenged in two
Member States), may therefore face a high or increased workload of preparing these analyses.
Domestic liberalisation in some Member States can be expected to have reduced the
administrative burden for international regular services. However, the patchwork of domestic
regulatory frameworks which has resulted from domestic liberalisation may also be expected
to increase the administrative burden for operators (especially SMEs) seeking access to more
than one domestic market for regular services since such access depends on different access
rules of each Member State.
Nonetheless, by introducing a maximum time-frame for consideration of applications beyond
which the application is approved by default, we consider that the Regulation is likely to have
resulted in more rapid authorisation of new international services, enabling operators to
exploit market opportunities more rapidly and offer new services of benefit to passengers.
Regulation 1073/2009’s impact on travel markets
We found a range of evidence that the market for regular international coach travel, as
measured by the number of international routes, service frequencies and/or passenger
numbers, has expanded over the last five years. It has proved difficult, however, to find
evidence which directly links this increase in activity to the introduction of Regulation
1073/2009.
On the limited and emerging evidence, domestic liberalisation appears to have created a
critical mass of operators who also introduce international services, resulting in a greater
impact on the number of international routes and service frequencies than pan-European
legislation alone. Following liberalisation of the German market in 2013, for example, local
start-up FlixBus has opened international routes to Denmark, Sweden and Belgium and
entered the domestic markets of Italy, France and the Netherlands. Some of its international
services do not have an origin, destination or intermediate stop in Germany. This suggests that
further liberalisation of domestic markets would strengthen the development of international
markets, quite apart from any benefits for passengers making domestic journeys.
There have been very few authorisations for cabotage within other Member States. This may
be because Regulation 1073/2009 automatically permitted cabotage on existing international
services, or that it is often implicitly or explicitly permitted by more liberal national, bilateral or
multilateral agreements, or that it is rarely the most commercially effective means of serving
both international and domestic passengers.
Regulation 1073/2009’s categorisation of coach services
Regulation 1073/2009 categorises international coach services as either regular, special
regular and occasional:
Regular services are scheduled services open to all passengers.
Special regular services are regular services not open to all passengers, such as those
taking people to school or to work.
Occasional services are all other services operated on the initiative of the customer or the
operator.
These definitions also appear to be well-understood in domestic markets, although the exact
boundary between them can be unclear. This may allow special regular services to compete
with regular services, despite in principle not being open to all passengers, or occasional
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services to be operated at high frequencies and regular intervals, effectively becoming regular
services.
Member States are not obliged to classify, regulate or monitor domestic services in this way
and do not always even distinguish coach and bus vehicles, let alone the many different types
of services provided by them. One consequence is that much of the data related to the
industry does not distinguish coach services from bus services, which are typically dominated
in urban and suburban areas by Public Service Obligation (PSO) operations.
Regulation 1073/2009’s reporting and monitoring arrangements
Regulation 1073/2009 introduced standardised documentation including Community licences,
required by each operator, and certified true copies of them, carried on each relevant vehicle,
and included a model of a Community licence. Member States may accept the Community
licence as valid for domestic transport operations. It also introduced standard authorisation
processes for regular international services and journey forms for occasional international
services. Model applications for authorisations and journey forms were provided in the
subsequent Regulation 361/2014.
Article 28 of Regulation 1073/2009 requires Member States to communicate to the
Commission the number of authorisations for regular services issued the previous year, the
number valid at the end of that reporting period, and the number of Community licences and
certified true copies.
In practice, this information is of little value in monitoring the market, as it indicates
permissions granted in the past, rather than either services operated in the present or the
extent to which they are used. The same international route may be authorised in some or all
the Member States through which it passes but still not be in operation in practice. For
example, there are 150 valid authorisations for routes to and from Sweden, but Swedish
statistics report that there are only seven international services.
These features of the liberalising approach of Regulation 1073/2009 contributed to the
difficulty of identifying the size of, or trends in, the international coach sector.
A wider issue is that liberalisation, including Regulation 1073/2009’s provision for the abolition
of control documents, tends to involve the simplification and removal of paperwork which
forms the basis of statistical analysis and reporting. In the long-deregulated regimes in Sweden
and the UK, and the newly-liberalising Germany, little reliable market data is available as a
consistent time series. In our view, there is a case for any further liberalisation to be
accompanied by measures to establish a harmonised, non-discriminatory and proportionate
system of collection, collation and reporting of industry data.
Terminals
Coaches are a flexible transport mode and, unlike trains and aircraft, are broadly able to pick
up and set down passengers anywhere with minimal provision of fixed infrastructure. Some
regular services make use of on-street stops to provide a range of pick-up and set-down
points. Others either find it commercially advantageous, or are required by local law, to pick
up and set down passengers in fixed terminals.
Few data are available on the number of coaches, or passengers, using terminals, and it is not
therefore possible to identify their relative importance on a consistent basis. Nonetheless, we
identified nearly 60 terminals, including at least one in each Member State, and found that all
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were served by local bus services and some were also served by, or close to, tram, metro or
rail services. Among the sample we examined, locations included the main railway station,
elsewhere in the city centre, by a suburban transport hub or railway station, and adjacent to
the motorway network, as well as some locations with no obvious relationship either to the
city centre or to other transport.
The range of facilities and onward connectivity which the majority of coach terminals provide
makes them particularly attractive (and important) for operators of long-distance coach
services where catchment areas for access and egress may be large, and where the propensity
for passengers to interchange between services is greater. In light of this, where access to
terminals is restricted whether through capacity constraints, secondary legislation (such as low
emission zones) or discriminatory practices this is likely to disproportionately impact upon
international operators.
Terminals are not defined in Regulation 1073/2009 but Regulation 181/2011 defines a staffed
terminal as “where according to the specified route a regular service is scheduled to stop for
passengers to board and alight, equipped with facilities such as a check-in counter, waiting
room or ticket office”. In practice, the facilities available at terminals vary and are often poor.
Some terminals appear to have adequate capacity for current services, particularly if they
were built at times when car ownership was lower. Others, such as in Germany, have found
that existing capacity has been rapidly exhausted following liberalisation. Some Member
States and cities, however, have no consistent provision of terminals and rely in whole or in
part on on-street stops.
Terminals may be combined with another transport facility such as a railway station, airport or
ferry terminal, or another building such as a shopping centre or office complex. They may also
offer a wide range of local bus services and long distance coach services and, at locations such
as airports, shuttle services to the city centre, between terminals, and to car parks, car hire
facilities and hotels.
Terminals may be owned and/or operated by national, regional or local competent authorities,
by coach operators, by railway infrastructure managers, ferry terminals and airports, or by
other private businesses. Their regulation may depend on national law, rules set by national or
local transport authorities, a local planning authority or a sector regulator. In a case study we
described how the coach terminals owned by Heathrow Airport Limited are regulated, by a
variety of mechanisms, by all these different agencies.
Stakeholders in a number of Member States have complained of potential, or actual, abuse of
dominance to limit access to terminals to provide international or domestic services. In some
cases an operator may be denied access to a terminal owned or controlled by an operator of
coach or rail services with which it might compete. Whether alternatives are either unavailable
or less attractive, this constitutes a barrier to entry to the market.
Persons with reduced mobility
One in six Europeans suffers from a disability and around one in twenty, or 5%, requires
assistance at transport terminals and on board vehicles. This includes between three and five
million people in each of France, Germany, Italy, Spain and the UK. These figures suggest that
PRM coach travel is a significant potential market, which could be exploited more effectively if
barriers to travel identified to us by stakeholders were addressed.
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Where one mode offers more frequent and faster services, the other may have the
characteristics of an “inferior good” and have to accept lower fares. Nonetheless, coach
operating costs are often less than those of rail, and coach fares can be less than €0.05 per
kilometre. At long distances, where air services are available, coach services can attract
passengers by not charging for heavy baggage, and may be viable when rail services are not.
1 Introduction
Purpose and scope of this report
Objectives
1.1 The European Commission (the Commission) commissioned this study in March 2015 to
provide a thorough review and analysis of the European coach industry, including domestic
long- and medium-distance services, international regular services, special regular services and
occasional transport. The study builds on the work and findings of the "Study on passenger
transport by coach in Europe" which we carried out for the Commission in 2009 through an in-
depth examination of the coach market supported by a structured programme of stakeholder
engagement and case-studies1. As far as possible, we build upon evidence gathered in the
previous study and draw comparisons in order to examine changes in the coach market
through time.
1.2 On 4 December 2011, shortly after the 2009 study, Regulation 1073/2009 came into force,
providing a set of common rules for access to the international market for coach and bus
services, and replacing Council Regulation (EEC) 684/92 and Council Regulation (EC) No 12/98.
Regulation 1073/2009 was intended to clarify and simplify rules and to improve enforcement
and avoid unnecessary administrative burden.
1.3 This study focuses on the coach market in all the 28 Member States of the European Union
(EU)2, describing the legislation and administrative practices defining the regulatory
framework for the sector and key elements of its structure and operation. More specifically, it
provides analysis of the following for each Member State:
the coach market including international and domestic routes;
the regulatory framework;
infrastructure issues, in particular concerning terminals for interurban coach transport;
and
issues related to disabled persons and persons with reduced mobility (PRM).
1.4 Given the problems encountered in the past concerning the collection of detailed statistical
transport data, this was excluded from the scope of the study.
1
The study reported in July 2009 and was based, wherever possible, on data for 2008.
2
Throughout this report, we refer to all 28 Member States of the EU as the “EU28”. Those countries
joining before 2004 are referred to as the “EU15” and those joining thereafter as the “EU13” or,
excluding Cyprus and Malta, islands with no international coach services, the “EU11”.
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Our approach
1.5 Our approach attempted to identify and gather detailed quantitative and qualitative evidence
against each of the headings in paragraph 1.3, and the specific requirements set out by the
Commission. We sought to:
Identify the main operators of inter-urban coach services, their characteristics (including
ownership and possible links to the rail sector), their size and their market shares, by
market segment.
Identify the main national and international routes, in terms of passenger-kilometres, for
regular and occasional services.
Determine the level of competition faced from operators not established in the same
Member State.
Analyse the regulatory framework (both in terms of legislations and administrative
practices) governing domestic services (e.g. the level of liberalisation, existence of long-
term contracts, public service obligations (PSO), cabotage operations etc.)
Analyse the observed obstacles for the development of the inter-urban coach market at
national or EU level, including obstacles in entering the market as well as possible
administrative burden.
Identify the most important coach terminals in terms of transport volumes and their
characteristics including the quality of the services provided, proximity to city centres and
connections to other modes of transport.
Analyse the regulatory framework and administrative practices regarding the use of
terminals by operators at local, regional or national level.
Understand the ownership of terminals and rules concerning the access to them,
including the identification of possible discriminatory practises.
Gather data on:
the number or percentage of disabled passengers transported by coach;
major obstacles to the transport of disabled passengers; and
good practices related to the access of disabled persons to coach.
1.6 Our approach included two principal strands of data gathering and analysis:
We carried out desk research and telephone interviews covering all 28 Member States.
We prepared more detailed case studies in ten Member States.
1.7 In addition to extensive and exhaustive desk research, we sought information from, and the
views of, the competent national authorities, operators and other stakeholders in all 28
Member States. Where specific data is not provided within this report, either it is
commercially confidential, would be disproportionately expensive and/or time-consuming to
compile, or does not exist.
1.8 Figure 1.1 summarises the responses we received from stakeholders in the four month period
to the end of November 2015.
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1.9 We contacted a total of 159 stakeholders in July 2015, at the beginning of the summer break.
In September we re-contacted stakeholders who had not yet responded, and by the end of
November we had received 73 complete or partial responses, an overall response rate of 46%.
1.10 As Figure 1.1 shows, response rates varied from over 65%, among operator associations and
regulator and competition authorities, to just over 20%, among operators3. Information
provided and issues raised by stakeholders have been included in the Member State case
studies and fiches attached as Appendices to this report. Additional detail regarding the
stakeholder engagement exercise is provided in Appendix D.
3
We did not ask stakeholders to provide an explanation for their decision not to participate in the
survey exercise. However, we expect the low response rate from coach operators may be due to a
combination of concerns regarding commercial confidentiality and an expectation that operator
associations would respond on their behalf.
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2.2 Regulation 1073/2009 further liberalised the provision of international coach services of each
of these types within the EU, through a number of procedures including Community licences,
authorisations and journey forms, which we discuss in detail in Chapter 5. It also permits
Member States to extend this liberalisation further, either unilaterally, bilaterally or
multilaterally, but leaves it to the Member States to decide the breadth and depth of any
further change.
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Source: Steer Davies Gleave analysis, categorisation and examples are illustrative.
Note: “bus or coach” column shows the typical vehicle type. Blank cells correspond to services that are not typically
classified in either EU or domestic legislation.
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2.4 As the table suggests, services may be operated by buses in some locations and coaches in
others, or by a mix of vehicles. This leads to a number of difficulties in locating and
interpreting data.
2.5 First, domestic “bus” services and “coach” services are defined or categorised differently in
some Member States, and not distinguished at all in others. This means that European
legislation, and statistics estimated, collected and available at the European level, frequently
refer to bus and coach together.
2.6 We agreed with the Commission that, for the purposes of this study, the definition of coach
services would cover all bus and coach services other than urban and rural regular scheduled
services, the top two rows in Table 2.2. This would mean that regular interurban, regular
international, special regular and occasional services would be regarded as coach services,
regardless of the type(s) of vehicle used.
2.7 Second, none of the Member States either formally distinguishes, collects data on, or provides
statistics on all the different types of bus and coach services listed in Table 2.2.
2.8 Third, international bus and coach vehicle-kilometres and passenger-kilometres are estimated
and reported in different, and mutually inconsistent, ways by different Member States. For
example:
Most Member States report, at most, “international vehicle-kilometres”.
Austrian statistics state that they cover only coaches operated by Austrian companies.
The Netherlands, uniquely, distinguishes vehicle-kilometres in the Netherlands by Dutch
vehicles and foreign vehicles, and vehicle-kilometres by Dutch vehicles in the Netherlands
and abroad (see Appendix B, Table B.37).
2.9 If each Member State reported operations by its national operators, as Austria has done, the
Netherlands would report 190.6 million vehicle-kilometres in 2014. If each Member State
reported operations in its territory (which would need to include services which did not even
stop there), the Netherlands would report 130.7 million vehicle-kilometres in 2014. In
practice, without evidence that the Member States have reported on a consistent basis, it is
not possible to compare directly, or add together, statistics on international services from
Member States.
2.10 In the next chapters we discuss in turn:
in Chapter 3, inputs to the European coach industry, in the form of operators, fleets and
employment;
in Chapter 4, outputs in the form of domestic coach services; and
in Chapter 5, outputs in the form of international coach services.
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Source: various, with some updating during February 2016. List of operators is not exhaustive. Detailed
investigation only undertaken for case-study Member States.
Note: shares estimated from routes/services, passengers, passenger-kilometres, vehicle-kilometres or fleet size.
Note: DE market share based on number of routes on 1 August 2014, source Bundesamt für Güterverkehr.
Note: FR market share based on number of routes, source goeuro.fr, August 2015.
Note: UK market share based on secondary sources.
4
See, for example, EU Air Transport Liberalisation: Process, Impacts and Future Considerations,
International Transport Forum, Discussion Paper No. 2015-04, January 2015.
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Fleets
3.9 Estimates of the size of coach fleets in the Member States may be available by at least two
means:
Member States sometimes identify the numbers of vehicles authorised or licensed to
provide domestic services.
Operator associations sometimes identify the total fleet size of their members.
3.10 We gathered information on the size of national coach fleets, summarised in Table 3.2.
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3.11 However, the same vehicle may be authorised or licensed to provide many of the types of
service listed in Table 2.2, and so the number of vehicle authorised or licensed may exceed by
a large margin the number of vehicles required to provide any specific category of service.
Vehicle registrations
3.12 The European Automobile Manufacturers Association (ACEA) provides data on new vehicle
registrations within the EU5, distinguishing medium buses and coaches, between 3.5 and 16
tonnes, and heavy buses and coaches, over 16 tonnes. ACEA also distinguishes EU15 and EU11
(EU-13 excluding Malta and Cyprus for which data is unavailable) Member States.
3.13 Vehicle registration data only provide information on the flow of new vehicles into the market,
rather than the absolute size of vehicle fleets. Nonetheless, the registration data give an
indication of the level of investment in different Member States over time.
3.14 Figure 3.1 shows the number of new buses and coaches registered within the EU between
1997 and 2014. Data for the EU11 are only included from the year prior to EU accession, which
has been labelled along the horizontal axis, although in practice we found no data for Bulgaria.
Figure 3.1: EU and EU15 new vehicle registrations of buses and coaches over 3.5 tonnes
Source: European Automobile Manufacturers Association (ACEA). No data for Bulgaria, Cyprus or Malta.
3.15 The number of vehicle registrations increased between 1997 and 2008, with a slight decline in
the early 2000s coinciding with a slowdown in economic activity. New registrations have
declined more substantially since the 2008 financial crisis and subsequent recession, and have
not yet started to recover. This is likely, in part, to be indicative of excess orders before 2008,
and we would expect that excess vehicles ordered prior to the economic slowdown are now
5
http://www.acea.be/statistics/tag/category/by-country-registrations.
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being brought into operational use from storage and therefore the demand for new vehicles is
being satisfied from existing stocks rather than from new orders.
3.16 Figure 3.2 provides equivalent data for buses and coaches exceeding 16 tonnes, which is likely
to be more representative of the coach market within the EU6.
Figure 3.2: EU and EU15 new vehicle registrations of buses and coaches over 16 tonnes
Source: European Automobile Manufacturers Association (ACEA). No data for Bulgaria, Cyprus or Malta.
3.17 The indicator shows far less volatility in the number of vehicles registered through time. This is
likely to reflect:
the greater influence of public sector funding on the bus market;
the substitution of travellers to coach from other modes during the recent economic
downturn; and/or
operators opting for smaller vehicles in response to the economic downturn and its
impact on the demand for coach travel.
3.18 New registrations within the EU15 Member States, which account for over 80% of all new
vehicle registrations, follow a similar trend to the EU total. A fall in registrations, however,
does not necessarily imply that the total stock of coaches is falling: it is equally possible that
the average age of the fleet has risen, with implications for fleet quality, as less new stock is
procured to replace the old.
6
Most Member States favour full size buses and coaches over 16 tonnes, which is therefore our
preferred pan-European indicator. The UK is unusual in having large numbers of 12-16 tonne single
decker vehicles (midi-buses), which may still seat 40-45 passengers.
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3.19 A detailed disaggregation of new vehicle registrations is only available for some Member
States, and is usually provided by representatives of vehicle manufacturers. Table 3.3
summarises data from the UK Society of Motor Manufacturers and Traders (SMMT).
Table 3.3: UK bus and coach registrations (2014 and 2015)
3.20 Figure 3.3 shows SMMT’s time series of UK bus and coach registrations by quarter.
Figure 3.3: UK big bus and coach registrations by quarter (2009-2015)
Source: SMMT Bus and Coach Registrations Monthly Report (7 January 2016).
Notes: big buses are defined as being over 8.5 tonnes, and coaches are defined as being over 16 tonnes.
3.21 This is consistent with the hypothesis that, at the EU level, coach registrations may have been
more stable than bus registrations during the economic downturn. In many Member States,
particularly in western Europe, where coach travel is often less attractive than rail travel, and
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may be an “inferior good”7, the economic downturn may have increased the demand for
coach travel as real household incomes fell and individuals switched from other modes to
coach. Alternatively, the financial crisis might have reduced prices and encouraged operators
to bring forward fleet renewal.
3.22 Figure 3.4 shows the number of new vehicle registrations per head of population for selected
EU15 Member States.
Figure 3.4: EU15 selected new vehicle registrations per inhabitant
3.23 For the EU as a whole, new registrations did not significantly increase or decrease until 2008,
and they declined significantly after this date. However, as the figure shows, the trends vary
by Member State:
In Italy and Sweden, there was a peak in new registrations in 2010/11, which coincided
with the implementation of Regulation 1073/2011.
In France, there was a more prolonged peak ending around 2011, which could also be
interpreted as coincident with preparation for implementation of the Regulation.
In Germany, in contrast, there was a sharp decline in new registrations after 2012, despite
domestic liberalisation on 1 January 2013, and despite a rapid growth in the number of
authorised long-distance regular coach services, shown in Appendix A (Figure A.1).
3.24 We conclude that it is difficult to interpret data on new vehicle registrations as evidence of
fleet expansion in preparation for, or in response to, liberalisation.
7
We have used the term “inferior good” here as defined strictly within economic terminology. In
economics, an inferior good is one for which demand falls when consumer income rises, and vice versa.
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3.25 Numbers of new vehicle registrations in the EU11 are relatively small and volatile and, as we
noted in paragraph 3.14, are only included from the year prior to EU accession. This makes it
difficult to examine them as a time series, but the data suggest that, for the EU11 as a whole:
There was a rapid increase in new registrations between 2003 and 2008 to a peak of over
6,300.
There was a fall to just over 3,500 after the financial crisis in 2008.
There has no evidence in the EU11 of the decline observed in EU15 since 2008.
3.26 A possible interpretation is that the recession has had little effect on the coach market in the
EU11. This is consistent with the number of new companies that have been established in
recent years including PolskiBus in Poland in 2011 and SuperBus in Estonia in 2015.
3.27 Figure 3.5 shows the average annual vehicle registrations in EU11 Member States, with the
year of EU accession shown in brackets.
Figure 3.5: EU11 new vehicle registrations, buses and coaches under 3.5 tonnes (2004-2014)
Fleet age
3.28 We have only found data on the age of bus and coach fleets for two Member States, the UK
and Spain, and the UK data only covers municipal bus fleets and is not relevant to this study.
3.29 Figure 3.6 shows the distribution of the Spanish bus fleet by year of registration.
3.30 The average age of the fleet is 13.1 years, and for national concessions the average age of the
fleet is 6.6 years. This suggests that the concession system results in, and may require, a
younger average fleet than would be provided in the market.
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3.31 We discuss our findings on the extent of provision for Persons with Restricted Mobility (PRM)
in Chapter 7.
Employment
3.32 We examined data from Eurostat from 2012, the most recent year with consistent data, on
employment in:
“Road passenger transport”: we understand that this includes all bus and coach
operations described in Table 2.2 and is often dominated by urban and suburban bus
services.
“Other passenger land transport n.e.c.”: this is reported as NACE 49.39.
3.33 However, we had two concerns about the “other passenger land transport n.e.c.” data.
3.34 First, it includes not only “scheduled long-distance bus services” (regular services), “the
operation of school buses and buses for transport of employees” (special regular services) and
”charters, excursions and other occasional coach services” (occasional services) but also
airport shuttles, operation of cable cars, funiculars, ski and cable lifts which are not part of
urban or suburban transit systems, and passenger transport by man- or animal-drawn
vehicles. We were concerned that it might include significant numbers of staff not involved in
the provision of coach services.
3.35 Second, it is possible that operators of a mixture of coach services and PSO local and regional
services allocate all their staff to one of these categories, which could materially distort the
overall data.
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3.36 We therefore also made “bottom-up” estimates of employment for the more narrowly-
defined coach industry which is the subject of this study. In some cases we estimated
employment from the size of fleet, assuming that operators have between three and four
employees per vehicle, and in other cases from aggregation of enterprise-level employee
numbers or estimates of full-time equivalent employees. Table 3.4 summarises the Eurostat
data and our own estimates.
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Other passenger
transport (2012)
road passenger
land transport
n.e.c. (2012)
Data from
AT 54,700 15,904
BE 18,000 7,002 7,000 Steer Davies Gleave estimate from TEC fleet (5,018) and employment (72%).
BG 33,600 10,276 5,000 Steer Davies Gleave estimate based on total bus and coach fleet size.
CY 3,000 526 250 Steer Davies Gleave estimate of Intercity Buses’ employees from fleet size.
CZ 38,300 10,107 Total number of “drivers” reported in 2012.
DE 366,100 72,836
DK 23,900 5,872
EE 5,700 2,714
EL 65,000 8,527 12,000 Steer Davies Gleave estimate based on total bus and coach fleet size
(KTEL and tourist coaches).
ES 179,100 51,170 17,896 Confebus estimates of direct employment in bus and coach sector, including
10,512 employed providing regular interurban coach services, and 7,384
providing occasional transport services.
FI 32,200
FR 250,400 101,335 94,300 “The road passenger transport sector” in 2013.
HR 10,500 5,956 4,573 Inter-county (not urban/suburban) employees in road transport in 2012.
HU 48,000 14,979 17,000 Domestic regional and long-distance bus and coach transport.
IE 12,500 6,236 2,000 Estimated from reported employees of Bus Éireann Expressway and members
of the Coach Tourism & Transport Council of Ireland.
IT 169,200 40,063 2,700 Ministry for Infrastructure and Transport estimates (2012) compromises
2,000 employees providing domestic services and 700 providing international
services. This figure is similar to the ANAV estimates (2012) of employment
within the long-distance coach sector (1,600 employees).
LT 15,100 1,648
LV 12,400 1,346
LU 4,600 2,890 2,200 FLEAA estimate of employment by coach and bus operators.
MT 1,500
NL 51,300 26,176 5,500 Drivers employed in private transport activities.
PL 138,900 41,147
PT 34,100 10,729
RO 78,100 20,496
SE 68,500 5,067 900 Steer Davies Gleave estimate of direct employees of coach operators.
SI 5,100 3,084
SK 18,400 4,229 8,000 Bus and coach company employees.
UK 250,100
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3.37 As a consistency check, we compare the data in Table 3.4 in Figure 3.7, which sorts the
Member States in descending order of number employed in other passenger land transport.
Note that, because of the wide variation between the largest and smallest estimates of
employment, the figure uses a logarithmic scale. This also means that an equal percentage
difference in two estimates results in an equal vertical spacing.
Figure 3.7: Estimates of coach sector employment
Road passenger transport Other passenger land transport Steer Davies Gleave estimate
1,000,000
100,000
Estimated employment (2012)
10,000
1,000
100
FR UK DE ES PL IT NL RO AT HU CZ PT BG FI EL BE IE HR DK SE SK SI LU EE LT LV CY MT
3.38 The chart suggests that other land passenger transport employs around one-quarter of the
number in road passenger transport. It also suggests that at least some of our “bottom-up”
estimates of employment are consistent with the other land passenger transport data. On
balance we concluded that the “other passenger land transport” data may be a reasonable
estimate of the numbers effectively employed in the coach industry.
3.39 In Figure 3.8 we estimate the trend in total employment in the coach industry over the period
2008 to 2013. The chart distinguishes two types of Member State:
For some Member States, data are provided in every year, and we have plotted as the
lower line the total reported employment from them.
For other Member States, data are only provided in some years, so we have extrapolated
or interpolated values from other years.
3.40 Note also that, in the case of the Czech Republic, we had no data, and therefore included the
number of coach “drivers” reported in 2012 and extrapolated from it values for other years.
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Member States providing consistent data Steer Davies Gleave estimated EU28 total
600,000
500,000
Number of persons employed
400,000
300,000
200,000
100,000
0
2008 2009 2010 2011 2012 2013
3.41 Figure 3.8 suggests that overall employment in the coach industry was in slow decline, at least
until 2013, the year in which the large German market was liberalised.
Key findings and conclusions
Operators
3.42 A number of operators are owned by major European transport or passenger transport groups
including:
national rail operators, such as Deutsche Bahn AG, ÖBB and SNCF; and
independent groups, including First Group, National Express, Stagecoach and Transdev.
3.43 Operators in many coach markets work through marketing alliances, partnerships, groupings
and subcontracting. The effective levels of dominance in states such as Sweden are therefore
higher than indicated by the largest operator share.
3.44 The extent of foreign operation of domestic services is obscured by the tendency of operators
entering a market to establish local subsidiaries or joint ventures. Patterns of ultimate
ownership, control, or the allocation of risk and profit can be complex, particularly if the
companies which own coach operators, in whole or in part, are themselves subject to merger
and acquisition activity.
3.45 There is clear evidence that liberalisation can lead to the rapid emergence of a dominant
operator or alliance, as happened in the UK after 1980 and appears to have happened within
two years in Germany. This, in turn, demonstrates a need for continued and careful
monitoring of domestic markets after liberalisation, if the benefits of liberalisation are to be
realised. At the same time, the challenges of monitoring markets effectively, given the lack of
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reliable data, in particular time series data collected on a consistent basis, suggests a need for
a well-defined reporting framework, possibly analogous to the Rail Market Monitoring Scheme
(RMMS) undertaken annually by the Commission. We return to this issue in the context of the
discussion of national regulatory frameworks in the next chapter.
Fleets
3.46 Operators can vary the size of their fleets either by buying new vehicles or by selling or
scrapping old ones. This provides them with flexibility, for example to deal with seasonal
variations in demand, by adjusting the relative scale and timing of additions to, or removals
from, the fleet.
3.47 For some Member States, estimates of the size of the active coach fleet have been made by
the national competent authority or by industry bodies. In others, the only source of
information is data on new bus and coach registrations collated by Eurostat.
3.48 These registrations of new buses and coaches in the EU appear to have fallen since the 2008
financial crisis. However, evidence from the UK suggests that falls in procurement of new
buses for the public sector may have concealed stable or growing purchases of new coaches.
Growth in new coach registrations after the financial crisis can be explained by a number of
factors:
The economic downturn may have increased demand where coach is an “inferior good”,
as travel shifts from other modes to coach.
The reduced demand for buses is likely to have depressed the prices of new vehicles,
enabling operators to bring forward renewal of coach fleets.
3.49 Within the overall trend, the apparent effects of liberalisation on new registrations are mixed:
In France and Sweden, new registrations peaked as Regulation 1073/2009 came into
force.
In Germany, new registrations fell rapidly after domestic liberalisation.
3.50 However, while the data examined demonstrate no clear relationship between liberalisation
and fleet size, we note that recent trends in fleet investment have been complicated by a
period of major recession at the beginning of the period investigated. The evidence from
France and Sweden suggests that liberalisation can encourage, or at least reinforce, plans for
investment. In addition, while the recession appears to have led to an excess stock of vehicles
in some Member States, we would expect those countries that have recently liberalised their
domestic markets to have generated more opportunities to increase fleet utilisation.
Employment
3.51 Eurostat data on “other passenger land transport n.e.c.” appears to provide a good indicator
of the volume of employment in the coach sector. Making some assumptions about missing
data, this appears likely to be in the range 0.5-0.6 million people across the EU, with a slow
trend decline over the period 2008 to 2013, as shown in Figure 3.8. This is consistent with
market growth being offset by productivity gains, and also implies that market growth is
required to sustain employment.
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Barriers to
terminals
reported
Member Latest Summary Largest operator
entry
State local share
law
AT Not liberalised: all services are either 60% No Yes
PSCs or five-year concessions.
BE Direct award of regional concessions 100% in each No, as few terminals exist.
to two incumbents. region
BG 1999 Fully liberalised. When no terminal space
available, mayors allocate
locations to operators.
CY 2009 Not liberalised. 100% N/A
CZ Fully liberalised. Community licences Other than at motorway Yes
and authorisations are issued by services, restrictions only
regional authorities. on safety grounds.
DE 2013 Liberalised if over 1 hour by rail or 53% No Yes
“50 kilometres between stops”. (by 2015)
DK 2005 Liberalised if no infringement of a
public services.
EE 2000 Not liberalised. Stops are Tallinn are
permitted, subject to the
agreement of the city
government.
EL 1996 Not liberalised. 100% N/A
ES 2009 Competition for national and regional 54% of national Yes, unless negotiated with Yes
concessions. concessions municipalities.
FI Liberalised.
FR 2015 Liberalised if over “100 kilometres Insufficient market No, as few towns have Yes
between stops”, otherwise assessed. stability to provide terminals.
meaningful
estimate
HR 2013 Regular at Counties’ discretion. Yes
Special regular liberalised.
Occasional liberalised.
HU 2012 Not liberalised. Any stops can be used if
safe, with landowner’s
permission, and if clearly
marked.
IE 2009 Liberalised.
IT 2005 Regular services are liberalised, but Illegal loading and Yes
regional services within one or two unloading outside
NUTS2 regions are subject to terminals has been
authorisation. reported.
LT Regular services are subject to No, except at route end
authorisation at national or municipal points.
level.
LU Too small for a commercial interurban
market.
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Barriers to
terminals
reported
Member
Latest Summary Largest operator
entry
State
local share
law
LV 2007 All interurban services are Stopping points may be
concessions. agreed with the competent
municipal authorities.
MT 2011 Too small for coach services. N/A N/A
NL 2000 Regular and special regular are all Yes
concessions: exemptions are
permitted but have not been sought.
Occasional liberalised.
PL 1988 Regular and special regular services
require authorisation.
PT 1990 Interurban services are liberalised.
Urban, suburban and regional services
are concessions.
RO 2011 Fully liberalised. No
SE 1993 to Liberalised if over 100 kilometres or 19% plus No Yes
1999 inter-county. “partners”
SI 2006 Regular only by PSO. Varies between urban
Special regular liberalised. areas.
Occasional liberalised.
SK 2012 Interurban services are liberalised Yes
subject to protection of PSO services.
UK 1980 Liberalised fully, except within 75-87% No Yes
London.
4.6 The date of the most recent legislation relating to domestic coaches varies widely, from 1980
in the UK to 2015 in France. Partly as a consequence, both the types of services which have
been liberalised and the extent of liberalisation vary widely between Member States. For
example:
Some have created a number of regional concessions, either by direct award or
competitively, with exclusive rights to operate services (e.g. Spain).
Some permit commercial operations, subject to rules designed to protect PSO services
(e.g. France).
Some permit commercial operations carrying passengers beyond a minimum distance
(e.g. United Kingdom).
Some delegate responsibility to regional, County or municipal authorities (e.g. Germany).
4.7 In addition, in different Member States, special regular and occasional services may variously
be liberalised, a national responsibility, or a regional responsibility with varying degrees of
liberalisation in different regions. For regular and some special regular services, for example,
variations include:
whether regional authorities consider regional coach services to be an extension of urban
and suburban services, operated by bus and other modes, or a distinct mode;
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where regional coach services are seen as a distinct mode, whether they are let as an
area-wide concession, procured through PSO contracts, or allowed to operate
commercially; and
whether local or urban authorities provide and/or designate terminals, or require
operators to use them, or permit them to stop on street, as we discuss further in Chapter
6.
4.8 This means that barriers to market entry can exist at a number of levels, ranging from tight
national control of services, through regional awards of concessions with exclusive rights
(whether directly awarded or competitively tendered), to local requirements for, or
prohibitions on, stopping in particular locations. We discuss barriers to entry further in Table
4.10.
4.9 Moreover, this patchwork of domestic regulatory frameworks may restrict the emergence of a
genuine internal market for road passenger transport services, may impose asymmetric
requirements upon domestic and non-domestic operators and, in the absence of reciprocity,
may permit operators extracting monopoly rents in closed domestic markets to cross-
subsidise (and potentially engage in predatory pricing practices) operations in liberalised
markets.
4.10 The number and diversity of regulatory frameworks across the EU deters coach operators
from providing international services. In particular, SMEs which have limited resources to
develop EU-wide business strategies will be disproportionately affected. Furthermore, since
domestic access rules in each Member State differ, the patchwork of regulatory frameworks
will impose an administrative burden on those operators seeking to provide regular services in
more than one domestic market.
4.11 In our desk research and stakeholder engagement we collected a wide range of information
from different sources including national, regional and local governments, stakeholders and
interviewees.
4.12 However, the variety of national regulatory frameworks results in a wide range of approaches
to the monitoring and reporting of the coach industry at the level of the Member States or the
regional or local competent authorities. In particular:
There is no consistent requirement for Member States, competent authorities or
operators to publish information on coach operations, other than as required by Eurostat.
Where Member States, competent authorities or operators do publish information, there
is no obligation for them to distinguish bus and coach services, or suburban and other
services, or PSO and commercial services, or regular, special regular and occasional
services.
4.13 In this section we summarise our findings and the extent to which we have been able to
characterise domestic services on a consistent basis. We discuss in turn information on:
the number of coach routes operated;
the disaggregation, where it exists, of data relating to bus and coach; and
the disaggregation, where it exists, of coach data to regular, special regular and occasional
services as defined for international services in Regulation 1073/2009 (see Table 2.1).
4.14 We then use this information to develop, to the extent possible with the data available,
estimates of market growth and market size.
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4.16 The only time series data that we have found, for Germany, shows that domestic liberalisation
on 1 January 2013 was followed by rapid expansion in the number of domestic long-distance
regular routes, as we discuss in greater detail in Appendix A.
Domestic coach passengers
4.17 In Appendices A and B, we report a range of data on domestic coach passengers, provided by
the Member States, either as a time series or disaggregated by market sector. We understand
that estimates of coach passengers using regular services are normally based on either:
coach driver counts of the number of passengers boarding each service; or
operator records of the number of tickets sold.
4.18 For special regular and occasional services, however, there may be no need to issue tickets to
individual passengers, and the only record of passenger numbers may be if driver counts are
made.
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4.19 In Table 4.3 and Table 4.4 we summarise data which we are able to present on a comparable
basis.
Table 4.3: Domestic passengers by year (thousands)
Member State 2009 2010 2011 2012 2013 2014 Average Services as
percentage described in the
annual source data
change
BG Bulgaria 112,314 103,987 104,107 101,390 100,798 -3% Long-distance and
international
transport
HR Croatia 56,419 52,561 52,293 54,292 54,000 -1% Interurban and
international and
occasional services
CZ Czech 39,590 38,338 34,576 37,225 34,832 -3% Interregional (non-
Republic PSO) services
33,365 33,051 35,462 29,310 26,434 38,375 3% Occasional
EE Estonia 4,725 4,495 4,462 4,586 4,584 4,437 -1% Regular "highway"
lines
2,134 2,192 3,204 3,869 3,195 4,466 16% Non-scheduled
transport
IT Italy 7,040 6,826 -3% National regular
services
PT Portugal 14,518 10,019 10,665 10,439 -10% Special regular
10,079 7,243 9,031 10,249 1% Occasional
ES Spain 19,857 18,874 18,483 18,189 16,809 16,075 -4% Long-distance
regular
668,099 659,453 651,132 659,318 647,045 635,914 -1% Suburban and
medium distance
383,852 361,071 337,588 332,444 347,233 325,335 -3% Special regular
185,672 180,139 175,618 158,492 156,327 162,852 -3% Occasional
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4.22 In general, Table 4.3 shows only small changes in the sizes of the reported segments, with two
notable exceptions:
In Portugal, the volume of special regular services declined by an average rate of 10% per
annum from 2011 to 2014.
In Estonia, the category of “non-scheduled transport”, which may approximate to
occasional services, more than doubled in size between 2009 and 2014.
4.23 The general decline in demand indicated by these data is consistent with the impact that we
would expect from the combination of a major recession at the start of the period and both
slow and variable rates of recovery thereafter. However, as shown in Figure 3.8, employment
in the coach industry has been relatively stable during the recession.
Domestic coach passengers by market sector
4.24 Table 4.4 focuses on the information in the latest available year in each Member State,
including the most recent data available in Table 4.3. It summarises any market disaggregation
between bus and coach, or within coach, that we have been able to deduce from the source
data.
4.25 We found at least some disaggregation of information in 13 of the 28 Member States,
although the levels of both disaggregation and completeness vary widely:
Only six Member States, Austria, Germany, Estonia, Spain, Latvia and Poland, claim to
distinguish regular urban bus services from coach services.
Of these, only Spain reports regular, special regular and occasional services.
In practice, as we noted in paragraph 4.21, Spain includes all school services as “ special
regular”, resulting in an apparent volume six times larger than any other Member State
which reports special regular services.
We are also concerned that the large reported coach totals in Poland may in practice
include, and potentially be dominated, by urban buses, which are not reported separately.
4.26 We note in particular that only five of the Member States report a number of occasional
passengers and only four Member States report a number of special regular passengers. As we
set out in paragraph 4.18, this may because no tickets are issued, and passenger numbers can
only be identified from driver counts. Neither competent authorities nor Member States can
report data on passenger number unless such counts are both made and collated.
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Source: Steer Davies Gleave analysis of Member States’ data for the latest year available.
Note: in some Member States we found data on some coach markets but not on the total market.
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Member State 2009 2010 2011 2012 2013 2014 Average Services as described in
percentage the source data
annual
change
BG Bulgaria 6,931 7,041 7,515 7,112 7,527 2% Long-distance and
international transport
CZ Czech 1,734 1,647 1,539 1,502 1,551 -3% Interregional (non-PSO)
Republic services
2,992 2,873 2,895 2,902 3,800 6% Occasional
DK Denmark 3,748 3,835 2% Coaches and non-
scheduled buses
EE Estonia 598 607 546 569 587 662 2% Regular "highway" lines
275 236 286 360 315 270 0% Non-scheduled transport
ES Spain 6396 6,004 6,150 5,946 5,599 5,289 -4% National concessions
HR Croatia 3,284 3,145 3,249 3,507 3,648 3% Interurban and
international and
occasional services
IT Italy 3,431 3,728 9% National regular services
LT Lithuania 527 495 506 528 542 536 0% Regular long-distance
services
62 72 111 80 60 59 -1% Special regular services
282 266 266 284 321 331 3% Occasional services
NL Netherlands 4,506 4,425 4,533 4,077 3,921 -3% Occasional services,
estimated assuming an
average load factor of 30
PL Poland 24,386 21,600 20,651 20,012 20,040 21,449 -3% Non-urban bus and coach
services
PT Portugal 245 435 385 317 9% Special regular
635 630 793 950 14% Occasional
4.30 The estimates we found, for 11 of the 28 Member State, appear to be more stable than the
estimate of passenger numbers shown in Table 4.3. With the exception of “national” regular
services in Italy, for which we found only two years’ data, the major changes appear to be in
Portugal:
Estimated passenger-kilometres on special regular services almost doubled between 2001
and 2012, before declining to 2014.
Estimated passenger-kilometres on occasional services rose sharply after 2012.
4.31 Data reported by Lithuania are sufficient to allow us to estimate the mix of regular, special
regular and occasional passenger kilometres, which is shown in Figure 4.1.
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4.32 This suggests that there has been a broadly stable mix between regular and occasional
services, with some volatility in the estimated use of special regular services.
Domestic coach passenger-kilometres by market sector
4.33 Table 4.6 focuses on the information in the latest available year in each state, including the
most recent data available Table 4.5. It summarises any market disaggregation between bus
and coach, or within coach, that we have been able to deduce from the source data.
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Source: Steer Davies Gleave analysis of Member States’ data for the latest year available.
Note: in some Member States we found data on some coach markets but not on the total market.
4.34 We found data for a total of 12 Member States, although only Latvia both distinguishes regular
urban bus service and provides estimates for regular, special regular and occasional services.
These suggest that the mix of services in Latvia is similar to that in Lithuania shown in Figure
4.1.
Estimates of market characteristics
4.35 We examined the extent to which the Member States’ data in Table 4.3 to Table 4.6 could be
used to examine trends in market growth over the period 2009 to 2014. We found that there
was insufficient information to attempt to estimate the mix of regular, special regular and
occasional services, for which there is credible data for only one small Member State,
Lithuania (see Figure 4.1).
4.36 After review of the data for inconsistent or implausible values, we concluded that it would be
possible to make the following estimates:
Estimation of average 2014 domestic trip lengths in five Member States: Italy (using 2012
data), Estonia, Croatia, the Czech Republic and Portugal.
Estimation of average 2009-2014 growth in domestic regular services for three Member
States: Slovenia, Estonia and the Czech Republic.
Estimation of average 2009-2014 growth in domestic occasional services for six Member
States: Estonia, the Czech Republic, Portugal, Spain, Lithuania and the Netherlands.
4.37 We discuss our estimates and findings in turn below.
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Source: Steer Davies Gleave analysis of Member States’ data and additional assumptions for missing years.
4.39 The average domestic passenger trip length implied by the Member States’ data are typically
in the range of 50 – 150 kilometres. In Portugal the average journey on special regular services
is just 30 kilometres which appears broadly plausible if, for example, it relates to school
services in rural areas. In Italy, however, the implied average domestic passenger trip is almost
550 kilometres (in 2012) which should be considered unreliable8.
Estimates of growth in domestic regular services
4.40 Figure 4.3 overleaf shows our estimates of the growth in domestic regular services, where
possible in both reported passenger journeys and estimated passenger-kilometres.
4.41 In Slovenia, the reported number of passengers grew, but the estimated passenger-kilometres
fell, implying a much shorter average trip length. In the other Member States, the reported
number of passengers fell, but the implied average trip length rose slightly.
4.42 For the three Member States as a whole, we estimate that the reported passenger journeys
fell by 7% and the estimated passenger-kilometres fell by 10%.
8
This is almost the distance from Rome to the Swiss border and would imply that large numbers of
passengers were travelling much of the length of the country, which maps of the long-distance network
(see Appendix A, A.231) suggest is unlikely to be the case.
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Source: Steer Davies Gleave analysis of Member States’ data and additional assumptions for missing years.
4.43 Figure 4.4 shows our estimates of the growth in domestic occasional services, again where
possible in both reported passenger journeys and estimated passenger-kilometres.
Figure 4.4: Domestic occasional services: growth in reported passengers (2009-2014)
Source: Steer Davies Gleave analysis of Member States’ data and additional assumptions for missing years.
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4.44 Estonia reported a more than doubling of passenger journeys, with a slight decline in
estimated passenger-kilometres, on “non-scheduled transport”, which we have taken to mean
occasional services. This implies that average passenger trip lengths have more than halved in
length. In Portugal, in contrast, there has been an implied near doubling in passenger-
kilometres but little change in passenger journeys, suggesting that they have almost doubled
in length. It is difficult to be confident that trip lengths halving in Estonia and doubling in
Portugal are plausible, or to identify what may account for them.
4.45 For the six Member States as a whole, we estimated that the reported passenger journeys fell
by 8% and the estimated passenger-kilometres rose by 9%, implying that the average trip
length rose by almost 18%.
Estimates and comparisons with 2008
4.46 We attempted to estimate the total size of the domestic markets of the Member States using
the data reported by them but, as Table 4.3 and Table 4.5 show, few Member States provide
any means of estimating total activity in the coach market.
4.47 The only source of coach-related data which we have for nearly all Member States is the
estimate of 2012 employment in Table 3.4, based on Eurostat’s “other passenger land
transport n.e.c.” data9. We attempted to use this as a basis to estimate EU28 passenger-
kilometres, vehicle-kilometres, passenger journeys and fleet size, as we describe below.
Estimate of EU28 passenger-kilometres
4.48 We compared this estimate of total coach sector employment with the 2014 market size for
the four Member States (Estonia, Croatia, Lithuania and Poland) for which we had an estimate
of the domestic coach market size. We calculated that the average estimated passenger-
kilometres per employee was around 525,000 ( although it varied between them by a factor of
almost two to one). We made assumptions regarding the number of employees in the Czech
Republic, Finland, Malta and the UK, for which no data were available for Table 3.4.
4.49 Multiplying our estimates of employment by our estimates of passenger-kilometres per
employee, we estimated the size of the 2014 domestic market as 285 billion passenger
kilometres, with a margin of error of at least ±25%.
Estimate of EU28 vehicle-kilometres, passenger journeys and fleet size
4.50 We attempted to use the same approach to estimate EU28 vehicle-kilometres, passenger
journeys and vehicles per employee, but found that these could vary by a factor of ten or
more among the Member States for which we had data. We concluded that the methodology
used to derive the estimate of market size could not be used to produce estimates of these
market characteristics.
Summary of estimates
4.51 In Table 4.7 we summarise the estimates we were able to make, and compare them with the
central estimates for 2008 shown as Table 1.2 of the 2009 report.
9
This disaggregate employment data series was not available at the time of our 2009 report.
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Source: Steer Davies Gleave analysis, 2009 and 2016, all estimates are indicative.
Note: employees in coach from Table 3.4 and Figure 3.8.
4.52 Our estimates of passenger-kilometres in the domestic market in 2008 and the domestic and
international markets in 2014 are similar. This indicates that the size of the market has
remained broadly constant. This is consistent with the pattern of recession and slow recovery
observed since 2009 and with the slight decline in employment over the same period. It
suggests that the coach market has been relatively stable during the recession, although
suppression of income levels across much of Europe is likely to have limited the ability of the
industry to exploit the benefits of international and, in some Member States, domestic
liberalisation since 2009.
4.53 Our estimates suggest that employment in the domestic and international coach industry in
2014 was approximately one-third of the employment in the domestic and international bus
and coach industry in 2009.
Domestic coach fares
4.54 We found no time series data on either fares or yields for any specific coach journey. We
therefore attempted to examine fares in domestic coach markets by two means:
estimating changes in average yield per passenger-kilometre; and
examination of actual fares on a sample of routes.
Changes in average yield
4.55 One potential source of time series data on coach fares is passenger revenue and estimated
passenger-kilometre data reported by operators. In practice, however these data are rarely
reported and, where they are, they may be misleading for a number of reasons. For example:
They may include all operations, rather than just coach services.
Aggregate coach revenues and passenger volumes may conceal variations in yields
between services and routes.
Trends in average yield may not reflect trends in average fares.
4.56 Historic average yield data is difficult to obtain for European coach companies. Many do not
provide annual reports which report both revenue and passenger numbers, and where this
information is provided it often includes not only coach but other transport services. However,
Table 4.8 and Figure 4.5 show our estimates of average coach yield data for ALSA (Spain), ÖBB
Postbus (Austria) and Swebus (Sweden).
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Source: National Express Group, Nobina and ÖBB Annual Reports, Ministerio De Fomento.
Note: We estimated ÖBB Postbus revenue from ÖBB-Personenverkehr revenue and an assumed ratio between
typical train and bus fares.
4.57 A large proportion of ÖBB Postbus’ services are short distance services in rural areas, many of
which have no other means of public transport. The average yield is significantly lower than
Swebus and ALSA, who operate longer-distance intercity services. Without estimates of
passenger-kilometres it is not possible to infer the actual relative levels of fares.
Figure 4.5: Index of growth in average yield (2012-2014)
4.58 ALSA and ÖBB Postbus largely operate services under public service contracts with limited
competition within the market and increased average yield by approximately 5% per year over
the same period.
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4.59 In contrast only Swebus, which provides services in a liberalised domestic coach market,
experienced a fall in average yield between 2012 and 2014. It is not possible, however, to
identify whether this reduction in yield resulted from either:
the operator lowering fares; or
a larger proportion of passengers on journeys with lower fares per passenger-kilometre.
4.60 This evidence is consistent with a hypothesis that market liberalisation reduces fares, but we
stress that we have only estimates of the average yield for three operators operating in
environments where a range of other factors may have affected trends in average yield.
However, coach services in Sweden have long been deregulated, and Swebus and partners are
the dominant operator. The recent fall in yields may be an effect of the recession rather than a
result of a change in levels of competition.
Evidence of actual fares
4.61 We sampled fares for a number of interurban routes, which we defined as involving a journey
from the capital city to another major urban area over a distance less than 300 kilometres,
listed in Table 4.9.
Table 4.9: Domestic services: sample of interurban coach journeys
4.62 We included both peak single fares and off-peak return fares and recorded data for booking
one day, one week and one month ahead. Our findings on interurban coach fares, which we
stress are for a single illustrative point-to-point journey and may not be representative, are
summarised in Figure 4.6.
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Figure 4.6: Domestic regular services: fares for interurban coach journeys
€0.10
€0.05
€0.00
AT ES EL PT SE FR UK DE IE FI IT HU BG HR LT RO LV PL CZ
EU15 EU13
4.63 Fares per kilometre, expressed in purchasing power parity (PPP) adjusted euros, varied from
€0.15 in Austria to less than €0.01 in Finland, on the Helsinki-Turku corridor. The small
differences between the cheapest and most expensive fares suggest very little variation by
time of day, few discounts for return travel and/or limited yield management. Poland is the
only Member State outside the EU15 in which our searches found a wide variation in fares.
4.64 Figure 4.7 overleaf compares the cheapest coach and rail fares for the routes listed in Table
4.9. In many Member States, the cheapest PPP-adjusted coach and rail fares per kilometre are
similar. In the UK, Germany, Finland and Italy, among the EU15, and Poland, among the EU13,
coach fares can be considerably lower than rail fares. In most other EU13 Member States,
coach fares can be higher than those of rail, particularly in Bulgaria, Latvia and the Czech
Republic. These findings are broadly consistent with our comparison of the cheapest coach
and rail fares for international journeys, in Figure 5.15 and Figure 5.16, which suggested that
either mode may be more expensive where it offers faster or more frequent services and
hence has market power.
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Figure 4.7: Cheapest fares for interurban coach and rail journeys under 300 kilometres
Cheapest single, return or advance (coach) Cheapest single, return or advance (rail)
€0.25
€0.20
PPP-adjusted fare per kilometre
€0.15
€0.10
€0.05
€0.00
AT ES EL PT SE FR UK DE IE FI IT HU BG HR LT RO LV PL CZ
EU15 EU13
Source: coach and rail operator websites, Steer Davies Gleave analysis.
Note: fares are for a single illustrative station-to-station journey and may not be representative.
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Barriers to entry
4.67 Our research, and comments from operators, operator associations and competent authorities
revealed a number of barriers to entry in Member States, summarised in Table 4.10. We
discuss issues of access to terminals further in Chapter 6.
Table 4.10: Domestic services: barriers to entry by Member State
PSC terms
terminals
Access to
Capacity
limited
Unfair
AT Austria Yes Yes ÖBB Postbus is owned by the national rail operator ÖBB:
For PSCs, one new entrant claimed that competitive tenders favour
ÖBB Postbus, as services must begin in a short period which in practice
only it can meet.
Commercial services are permitted where rail operator ÖBB does not
object, giving it the power to permit services by ÖBB Postbus but not
by other operators, creating scope for discrimination.
CZ Czech Yes Anecdotal evidence of complaints and disputes arising between operators
Republic and terminal owners regarding the level of fees.
DE Germany Yes Since liberalisation, there has been widespread lack of terminal capacity.
ES Spain Yes Concessions are long and stakeholders argue that incumbents have better
access to market information and tend to be favoured.
FR France Yes The only suitable terminal space in many towns and cities is the railway
station operated by SNCF, which may refuse access to potential
competitors.
HR Croatia Yes Many terminals are operator-owned and they may deny access to
potential competitors. The number of complaints and proceedings has
increased recently because terminal owners will not publish timetables or
sell tickets for other operators.
IT Italy Yes Regional authorities both fund PSCs and approve any competition to them.
SE Sweden Yes Stockholm’s main terminal Cityterminalen is congested and, while it is
operated independently of operators and without discrimination, this
limits scope for new entry.
SK Slovak Yes Discriminatory practices intended to protect incumbent operators have
Republic been reported.
UK UK Yes Disputes related to access to London Luton Airport resolved in the courts.
Dispute related to access to Stansted Airport being examined by the
competition authorities.
Yes London’s Victoria Coach Station, also operated independently of operators
and without discrimination, is congested.
4.69 In addition, some Member States appear to require that operators of domestic coach services
are locally established, constituting a further potential barrier to entry for operators from
other Member States.
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4.70 We note a diverse range of concerns raised by operators, operator associations and, in some
cases, competent authorities regarding access to terminals:
In Austria and France, it was argued that a terminal owner who was also an operator
might discriminate against other operators, although no specific claims were made that
this had happened.
In Croatia, terminal operators may deny access to potential competitors, although no
specific claims were made that this had happened.
In the UK, there have been complaints about airports terminal operators granting access
rights to some operators but not to others, which have been pursued in the courts or with
the competition authorities10,11.
In the Czech Republic, there were disputes relating to fees.
In Germany, Sweden and the UK, there were observations that terminals with non-
discriminatory access criteria were now having to exclude operators through lack of
capacity.
4.71 Other than in relation to terminals, the European Association for Coach Tourism (EACT)
claimed that a number of artificial barriers currently limit the expansion of tourism by coach
across the EU, and in particular:
At tourist attractions or coach parks across the EU, very few facilities exist for the safe
loading and unloading of passengers with reduced mobility (PRM) from coaches that have
been built to carry wheelchair passengers. We discuss this further in Chapter 7.
In central city tourist areas, coach operations are often restricted and are unable to use
bus only lanes. There is also a lack of dedicated coach parks close to tourist attractions
and of dropping off/picking up locations outside hotels.
4.72 EACT also pointed out that, in contrast to air and sea passenger transport, international coach
and rail transport is not exempt from VAT provisions.
Key findings and conclusions
The national regulatory frameworks
4.73 Member States have adopted a number of approaches to how domestic coach markets, where
they exist, are regulated, categorised and monitored. In different Member States, coach
10
London Luton Airport had for 30 years allowed bus and train transport service operator Arriva to
operate a bus service to London Victoria. In May 2013 the airport stopped giving Arriva access to the
airport bus station, and instead granted National Express, which also provides bus and train services, an
exclusive concession in exchange for a significant proportion of National Express' passenger revenue.
This agreement, due to run for seven years, also granted National Express the right of first refusal over
the operation of other services on routes between the airport and other destinations in London. In
January 2014 the court determined that the terms of the agreement with National Express represented
an abuse of dominance by Luton Airport. (Source: Oxera)
11
London Stansted Airport has recently withdrawn access rights to its coach terminal for operator
Terravision. The company has launched a legal action in an effort to have its access rights restored,
accusing the airport of abusing its dominant position under the 1998 Competition Act and restricting
competition to the detriment of consumers. The company has also lodged complaints with the
Competition and Markets Authority (CMA) and the Civil Aviation Authority (CAA).
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extent from air and rail. They have many stops in the Baltic States and are operated by
companies including Ecolines, Lux Express and PolskiBus.
Long-distance routes, such as to and from Germany, the Netherlands and Belgium, are
almost all provided by carriers operating under the Ecolines brand. These routes face
strong competition from airlines that outperform Ecolines on frequency, seat capacity,
and travel time, and therefore coach services must compete on price.
5.5 Over the long-distance corridor crossing the Baltic States and extending to western Europe,
rail competition is weak. This is due to a range of factors, including the following:
The “lumpiness” of rail capacity means that trains provide excessive capacity and/or a low
frequency.
The dominance of rail freight services, particularly within the Baltic States, limits capacity
for passenger services and extends journey times.
The quality of service is often outdated, with old rolling stock, poor station facilities and
limited interchange opportunities.
5.6 International rail services also suffer from additional competitive disadvantages, in particular
infrastructure issues which adversely affect operators’ ability to provide rail services. For
example, differences in railway gauge between Poland and the Baltic countries introduce
barriers to through traffic to/from western Europe. Cross-border rail services between Poland
and Lithuania are very limited and, as a consequence, international rail passenger journeys
require more interchanges and longer journey times than direct coach connections. On a
number of domestic routes in Latvia (such as between Riga and Liepaja, Ventspils, Renge and
Gulbene) coaches have therefore replaced rail services.
5.7 However, both domestic and international rail may become competitive against coach again
when the Rail Baltica project, one of the priority projects within the EU TEN-T programme of
initiatives, is completed. The project is intended to upgrade the rail link between Finland, the
Baltic States and Poland, with the aim of improving the connection between Central and
Northern Europe. It will enable a continuous high speed rail link from Tallinn to Warsaw via
Riga and Kaunas. The project is estimated to be completed by 2024.
5.8 Over longer distances, coach services face competition from airlines that can offer better
journey time, seating capacity and often frequency. Coach services, however, have a number
of competitive advantages over air travel:
Coach services are likely to serve locations closer to the origin and destination of
passengers, as they connect many more pairs of cities and towns than air services. For
example, almost all coaches departing to the west of Riga make a detour to Vilnius and
stop at all major towns en route to Warsaw.
Coach travel is generally cheaper than air travel for travel at short notice, when airfares,
including those of the low cost airlines, are generally high. For example, air fares between
Berlin and Riga at short notice are close to €200, while coach fares are typically €50-75.
Moreover, there is evidence that some airlines restrict online booking for travel to and
from the Baltic States for departures within a week due to credit card fraud risk.
While charging for checked-in luggage is a major revenue source for most airlines, coach
companies do not currently charge for luggage and the luggage size regulations are less
strict. This results in a large travel cost saving for those passengers planning a longer
duration visit, such as guest workers and students.
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5.9 A number of companies operate international coach services over the corridor from Berlin to
the Baltic States. The most important are Ecolines, Lux Express and PolskiBus, which we
discuss in turn below.
Ecolines
5.10 In 2013, Ecolines carried approximately 500,000 passengers on an international network
connecting more than 150 destinations, mainly in Central and Eastern Europe (see Figure 5.1)
and with a fleet of more than 200 vehicles.
Figure 5.1: International networks: Ecolines
Source: www.ecolines.net
5.11 Ecolines is a long-distance coach service provider founded in Latvia as Norma-A in 1993, when
the rules on domestic coach competition with rail were relaxed. The relevant legislation, the
Law of the Republic of Latvia on Competition and Restriction of Monopolies, was passed in
December 1991 and amended in 1993. This provided the basis for competition legislation and
described the responsibilities of the major competition authority, the State Anti-Monopoly
Committee. Norma-A introduced the brand “Ecolines” in 1997 after various bus companies
based in Russia, Belarus, Bulgaria, Estonia, Lithuania and Ukraine joined the organisation.
5.12 Table 5.1 sets out a brief chronology of the evolution of Ecolines services.
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Year Event
2000s Ecolines began the provision of services to West Europe with services to Germany, the Netherlands,
Belgium, France and the UK.
2004 After the enlargement of the EU to include ten new Member States including the Baltic States, Ecolines
expanded its offer to Western Europe. To meet the demand for travel by citizens of the Baltic States in
looking for work in the UK and Ireland, a route was launched serving London, Birmingham, Nottingham,
Leeds, Manchester, Liverpool, Holyhead and Dublin.
2004 Ecolines introduced other major changes in its business strategy, including online ticket sales, expansion
of services within the Baltic market, and a “one-price policy” for international trips, setting the same
ticket price for all the cities in one destination country regardless of distance from the starting point.
2005 The link to the UK was further expanded when a route from Riga was launched serving Preston, Carlisle,
Glasgow and Edinburgh. These routes have since been discontinued and the only UK city currently
served is London.
2009 Ecolines launched more than 100 new intercity services.
2011 After labour market opening in Germany, Ecolines substantially increased services to Germany, with 25
services per week to each of 40 German cities to meet the higher demand for travel from the Baltic
countries to Germany. A new route from Riga via Berlin to Aalborg in Denmark was also launched.
Lux Express
5.13 Lux Express was established in Estonia in 1993 as MootorReisi AS, to operate services in
Estonia, Latvia, Lithuania and Germany. From 2010, it has operated under the name of Lux
Express Group and focuses its offering on international coach routes. At present, the company
serves more than 50 destinations to and from Central and Eastern Europe (see Table 5.2 and
Figure 5.2). Over the four years from 2010 to 2013, Lux Express almost doubled its patronage
from approximately 375,000 to 720,000 passengers.
Table 5.2: International coach destinations served by Lux Express
Source: www.luxexpress.eu.
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Source: www.luxexpress.eu.
5.14 Lux Express Group also operates a low-cost service under the brand Simple Express. The
decision to differentiate the brand to provide low-cost services was driven by evidence that
demand for trips by bus was substantially increasing in two main markets: small and medium
enterprises looking for ways to reduce the cost of business trips, and young people seeking to
travel for as little as possible. Simple Express was launched in April 2010 on the Riga-Kaunas-
Warsaw route. Table 5.3 summarises recent developments.
Table 5.3: International coach services of Simple Express
Date Event
2010, summer Simple Express began offering services from Tallinn and on the Riga-Tartu route.
2010, December A new route between Riga and St. Petersburg was launched.
2011, February Services began on the new route between Riga and Vilnius.
After the December 2011 entry into force of Regulation 1073/2009, Simple Express began
2012, June providing services to/from Germany on the new Warsaw-Berlin route, which carried 92,000
passengers in 2013.
2014, May A new route from Vilnius, via Warsaw and Wrocław, to Prague was launched.
2015, October The domestic network was enlarged to serve 18 towns in Estonia.
5.15 Simple Express specialises in providing low-cost international bus services from/to the Baltic
States. Riga-Kaunas and Riga-Tallinn fares are around €10 and Riga-Warsaw fares are around
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€20. In June 2011, Simple Express began a price war against its competitors, lowering the fare
on the Vilnius-Warsaw route to less than €3, and this price was also offered to the first five
passengers on each coach on all routes. At the end of 2015 the company introduced a new
dynamic pricing model inspired by the practice of low cost airlines, offering tickets starting
from €1.
5.16 Cabotage operations by Simple Express services are currently cheaper than heavily subsidised
domestic Latvian services and almost twice as cheap as Lithuanian domestic services. It is
unclear whether the Simple Express fare schedule represents a long term profit maximising
strategy, or whether in the short term fares are being offered below costs in order to capture
market share. If such fares are sustainable in the long term, however, this pricing strategy is
likely to result in a further decrease of average fares on international routes along the
corridor.
PolskiBus
5.17 PolskiBus is an express coach operator controlled by Souter Investments (the private
investment office of the Scottish coach operator Stagecoach Group), which began services in
June 2011, broadly concurrent with Regulation 1073/2009 entering into force. PolskiBus
started operations on eight routes serving 16 towns in the domestic Polish market and four
international capitals (Berlin, Bratislava, Prague and Wien). It currently operates services on 19
routes including international services to/from destinations now including also Budapest,
added in December 2015 (see Figure 5.3).
Figure 5.3: International networks: PolskiBus
Source: www.polskibus.com
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5.18 When the service was launched in June 2011, PolskiBus had a fleet of 18 coaches. The fleet
was enlarged to 68 coaches in February 2012, when the domestic offer was enlarged and a
new connection between Warsaw and Berlin Schönefeld airport was introduced. The fleet was
further expanded to 132 coaches between 2013 and 2014. PolskiBus’ coaches are capable of
carrying up to 70 passengers, feature Euro 5 emissions standards and offer free WiFi, leather
seats and air conditioning. Its passenger numbers reached 1 million in its first year, 3 million in
its second year and 8 million in its third year.
5.19 PolskiBus uses pricing methods employed by low cost airlines. Tickets can only be bought
online and prices begin at €1. In March 2015, Lux Express Group started to operate cabotage
services in the Polish domestic market and currently offers a number of services. In response
to the entry of Lux Express in March 2015 on six domestic routes in Poland, PolskiBus lowered
the fare on the Warsaw-Krakow route. This prompted a further response by Lux Express,
initiating a price war between the two companies. Fare competition is expected to continue as
Lux Express plans further expansion in Poland.
5.20 PolskiBus launched the Warsaw-Vilnius route in September 2014, and the frequency was
increased to three services per day in July 2015. In September 2015 the route was lengthened
to serve Riga and Tallinn from Warsaw, and a new sister company called SuperBus was created
to operate the service. In January 2016, however, the service was suspended due to limited
patronage. It has since been announced that SuperBus will focus on Estonian domestic routes
and it is not clear whether the Warsaw-Vilnius connection will be restored.
The Paris to Milan corridor
5.21 Paris in France and Milan in Italy lie 640 kilometres apart, but 850-900 kilometres apart by
road because of the topography of the Alps. The cities are connected well by air and rail:
There are currently 18 flights per day in each direction, down from 20 in 2014 and 23 in
2011.
There are three direct TGV train services per day, with a journey time of 7 hours 10
minutes, and a daily sleeper service provided by Thello.
5.22 Before 2011, only the incumbent international coach operator Eurolines, established in 1985,
provided regular coach services. The market was restricted to cross-border traffic, and no
cabotage was permitted within France.
5.23 After Regulation 1073/2009 came into force in 2011, Eurolines became the first international
operator to receive permission to operate long-distance regular coach services within France.
Competing with French domestic rail services for the first time, it supplemented cross-border
traffic with domestic passengers, such as between Paris and Lyon.
5.24 However, additional conditions imposed on cabotage operations in France were that, over a
year:
Domestic passengers carried through cabotage could not contribute more than 50% of the
passengers or 50% of the turnover on any given route.
Cabotage operations were not allowed between stops located within the same region.
5.25 In July 2012 SNCF, the French state railway, established a coach subsidiary iDBUS (now
OUIBUS) and began commercial services. In December 2012, after securing a second hub at
Lyon-Perrache, it began to operate three Paris-Lyon-Milan services a day, since reduced to
two.
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5.26 Despite Regulation 1073/2009’s creation of cabotage rights, in 2013 the French Autorité de la
concurrence (the competition authority) recommended modernisation of the system of
administrative approvals for cabotage operations. It argued that the system was inefficient
and lacked transparency and, given that the French state is also the main shareholder of SNCF,
proposed an independent regulator for the coach sector.
5.27 The French domestic coach industry remained tightly regulated until the August 2015 Macron
Law12, which liberalised the long-distance coach market for journeys of more than 100
kilometres between stops. For journeys under 100 kilometres the newly-appointed
independent regulator (ARAFER) must assess whether the service poses an economic threat to
existing rail or road PSCs.
5.28 In July 2015, in anticipation of this liberalisation of the French domestic market, two new
operators began services on the Paris to Milan corridor:
From 8 July 2015, Megabus, a subsidiary of British operator Stagecoach, introduced two
through services per day serving London, Lille, Paris, Lyon, Turin and Milan.
Shortly afterwards, following its simultaneous entry to the Italian and French markets,
FlixBus, a privately-owned German business13, introduced three indirect services per day
between Paris and Milan requiring interchange at Strasbourg, Zurich or Frankfurt. We
note that end-to-end journey times via Frankfurt are long and this connection may attract
few passengers.
5.29 While new entry has increased passenger choice of journey times, service quality and fares, it
is not yet clear whether and how patterns of demand will change in response. There may also
be consequential impacts on the expansion, withdrawal or consolidation of coach operations.
Current and prospective operators identified a number of concerns regarding access to the
Paris to Milan corridor:
Outside France, there is an impression that the Macron Law will effectively favour French
companies, through retaining the requirement that revenue generated by domestic use of
an international service cannot exceed 50%.
In Italy, there is concern with the time required first to establish a new operator and then
to obtain the Community licence, certified true copies and route authorisations necessary
for international operations, which one stakeholder told us could take a cumulative total
of eight months.
Key findings from case studies
5.30 Taken together, the case studies illustrate a number of points.
5.31 First, coach operators can add and remove routes relatively easily, allowing them to enter
markets on a trial basis, or to modify services rapidly as markets change.
12
“Loi pour la croissance, l’activité et l’égalité des chances économiques” (Law for growth, activity, and
equal economic opportunities)
13
See also Appendix A. FlixBus does not own any coaches or employ any drivers. Instead it cooperates
with regional bus companies that are responsible for the day-to-day running of routes. FlixBus provides
the administration and permissions required to operate long-distance and international services
alongside network planning, marketing, pricing, quality management and customer service.
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5.32 Second, and as with domestic coach services, operators may act in partnerships, groups or
alliances if this enables them to offer a more effective network. Operators may provide, under
subcontract, international or cabotage services in a number of Member States.
5.33 Third, the provision of coach services, and their relative success, may depend on the
characteristics of competing modes including car, rail and air. These may change with further
investments in road, rail or airport infrastructure. However, coach is often able to serve more
stopping points than rail or air, because it need not be constrained by the need for expensive
fixed terminals.
5.34 Fourth, barriers such as the change of rail gauge, between the Baltic States and Poland, and
the Alps, between France and Italy, can hinder or help coach as a mode. However, even where
coach is slower, less frequent and less comfortable that other modes, its lower costs mean
that it can often remain in the market by offering lower fares, or by not charging for heavy
baggage.
5.35 Fifth, domestic coach market liberalisation in one or more of the Member States involved can
be the catalyst for the provision of new international services. Once a domestic coach market
has been established, some operators may choose to exploit their domestic position through
offering services to neighbouring countries. This allows them to differentiate their product
from domestic competitors and to encourage higher load factors which improve the efficiency
with which assets are deployed.
5.36 Sixth, coach services and networks can be dynamic, with competition sometimes leading to
price wars and the subsequent withdrawal or one or more operators.
5.37 In the following paragraphs we discuss the background European regulatory framework within
which the developments in these two case studies have taken place.
The European regulatory framework
5.38 Europe has a wide range of bus and coach services and, before either regulation or
liberalisation of the industry could be applied, it was necessary for the Commission to take
steps to define and categorise the market. Accordingly, and as already noted:
Regulation 684/92, on common rules for the international carriage of passengers by coach
and bus, subdivided them into four groups: regular services, special regular services,
shuttle services and occasional services.
Regulation 1073/2009, which repealed Regulation 684/92, removed the category of
shuttle services.
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5.40 Unlike the inconsistent approaches to reporting domestic services, highlighted in Table 4.4 and
Table 4.6, Regulation 1073/2009 provides a broadly clear and stable categorisation of
international services. We discuss next in turn below:
the standardised control documents provided for in the Regulation;
Member States’ reporting to the Commission, based on these control documents; and
other information on the scale and characteristics of the international coach market.
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5.42 Regulation 1073/2009 also permits Member States to extend this liberalisation further,
whether unilaterally, bilaterally or multilaterally:
Article 4 (8) allows that “Member States may decide that the Community licence shall also
be valid for national transport operations.”
Article 25 (1) allows that “Member States may conclude bilateral and multilateral
agreements on the further liberalisation of the services covered by this Regulation, in
particular as regards the authorisation system and the simplification or abolition of control
documents, especially in border regions.”
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5.43 In summary, while the Regulation leaves it to the Member States to decide the breadth and
depth of any further change, it permits further or even complete liberalisation, including the
abolition of control documents.
Regulation 361/2014
5.44 Regulation 361/2014 lays down detailed rules for the application of Regulation 1073/2009 as
regards documents for the international carriage of passengers by coach and bus. Annexes to
the Regulation set out models for:
I. journey forms;
II. cover pages for books of journey forms;
III. application forms for authorisations;
IV. authorisations;
V. certificates for international own account operation; and
VI. model communication for numbers of cabotage authorisations.
Reporting of statistics on Community licences and control documents
5.45 As we noted above, Regulation 1073/2009 specifically permits Member States to conclude
bilateral and multilateral agreements on the further liberalisation of the services covered by
the Regulation, in particular as regards the authorisation system and the simplification or
abolition of control documents. Where documents exist, however, Article 28 requires the
Member States to provide the Commission with regular returns, which we summarise below.
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Community licences
5.46 Each carrier wishing to provide international carriage of passengers by coach and bus requires
a Community licence issued by a competent authority in a Member State (see Table 5.5). Their
number can be seen as a measure of the number of operators wishing to operate international
services.
5.47 Figure 5.4 shows the number of Community licences held at the end of each year for the
period 2010 to 2014, as reported by Member States to the Commission.
Figure 5.4: Community licences (end 2010 to end 2014)
5.48 Community licences may be issued for renewable periods of up to ten years, and the change
over any period reflects not only new licences issued but also old ones expiring. The fall in
numbers between 2013 and 2014 is driven largely by falls in the number of licences in the
Czech Republic, Spain, France, Poland and Sweden, some of which may have been issued as
early as 2003. Nonetheless, the overall number of Community licences held has grown by
around 3% since 2010, with around 36,000 licences at the end of 2014, despite a period of
slow growth or even economic contraction in some Member States.
5.49 Figure 5.5 compares the number of Community licences held in each Member State at the end
of 2010 and the end of 2014.
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Figure 5.5: Community licences by Member State (end 2010 and end 2014)
5.50 While there has been a slow upward trend in the number of carriers holding a Community
licence, the most notable increase has been in Croatia which had no licences at the end of
2010, as it was not a member of the EU until 2013, and over 500 at the end of 2014. In
Romania almost 700 more Community licenses were held in 2014 than in 2010. During this
period Ordinance no. 27/2011 liberalised access to the road transport market based on the
principles of non-discriminatory and free competition.
5.51 The greatest percentage change (deviation from the diagonal line) in the number of
Community licences was in Estonia, where numbers rose from 238 in 2010 to 413 in 2014, an
increase of almost 75%. This may represent an increase in the number of licensed operators,
or may represent existing operators replacing a domestic licence with a Community licence.
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5.55 Figure 5.7 compares the number of certified true copies held in each Member State at the end
of 2010 and the end of 2014. The scales are logarithmic, so that equal percentage change
between 2010 and 2014 results in equal distance from the dotted line.
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Figure 5.7: Certified true copies by Member State (end 2010 and end 2014)
5.56 There have been no major changes in most Member States, although we identified a number
of outliers:
In Estonia, the number of certified true copies rose from 635 at the end of 2010 to 2,570
at the end of 2014, an increase of over 300%. In Denmark, the number of certified true
copies rose from 3,851 at the end of 2010 to 11,334 at the end of 2014, an increase of
nearly 200%. As we noted in paragraph 5.51 above, this may have been driven by a large
number of operators changing from national to Community licences and obtaining
certified true copies for all the vehicles in their fleets.
In the United Kingdom, the number of certified true copies fell from 17,936 at the end of
2010 to 14,127 at the end of 2014, a decrease of over 20%.
In France, over 90,000 copies were held at the end of 2014, almost sufficient to provide
one certified copy for every bus and coach in France listed in the Statistical Pocketbook
(see Table 3.2). This is far more than any other Member State and almost one-third of all
certified true copies in Europe.
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Authorisations
5.57 Each regular international service must have an authorisation (see Table 5.5), although Article
25 allows Members States to conclude bilateral and multilateral agreements on the further
liberalisation of the services covered by the Regulation, in particular as regards the
authorisation system. Their number can be seen as a measure of the number of international
services operated. At the end of 2014 there were 2,412 valid authorisations, summarised in
Figure 5.8:
The horizontal axis shows the valid authorisations issued by each Member State.
The vertical axis shows the valid authorisations citing each Member State as a destination.
Figure 5.8: Valid authorisations for regular international services (end 2014)
5.58 Figure 5.8 shows that the balance of authorisations issued to and from some Member States is
asymmetric. Note that the scales are logarithmic, so that equal percentage imbalance in
licences issued to and from each Member State results in equal distance from the dotted line:
Below the dotted line, Member States such as Denmark, and to a lesser extent Bulgaria,
Estonia and the UK, have large numbers of valid authorisations but are rarely cited as
destinations.
Above the dotted line, Member States such as Sweden, and to a lesser extent Ireland,
Greece and Italy, are often cited as destinations but have relatively few valid
authorisations.
5.59 This analysis may reflect a number of characteristics of the international coach market,
including:
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the relative attractiveness of Member States as a destination for coach travel (for example
the United Kingdom, as an island nation, may be unattractive as a destination for coach
travel relative to other modes);
the relative strength of domestic coach markets and the extent to which operators seek to
exploit the international coach market; and
the relative ease of securing authorisation to serve international markets (and hence a
proxy for market liberalisation) by Member State.
Figure 5.9: Authorisations: major imbalances by direction (end 2014)
5.60 Figure 5.9 examines in further detail these major imbalances in authorisations in different
directions between some pairs of Member States.
Belgium has 436 valid outbound authorisations, although it did not report the
destinations, but only 11 inbound authorisations.
The UK has 260 valid authorisations to Ireland, which dominate the total of 322 valid
authorisations, but Ireland has issued only 50 valid authorisations, all of them to the UK.
Denmark has a total of 312 valid authorisations to Sweden, Germany and Austria but only
nine in the reverse direction.
Bulgaria has 40 authorisations to Greece but only 4 in the reverse direction.
5.61 We have not identified clear reasons for these imbalances, which might in principle reflect the
perceived relative ease of applying for authorisations from one end of the route, which could
occur by various mechanisms:
It might be easier to apply in the Member State which most rapidly forwarded and
progressed an application.
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It might be easier to apply in the Member State where the requirements of the local
competent authorities were most onerous, if a local operator was familiar with their
requirements.
5.62 They might, alternatively, reflect the origins or administrative centres of the operators or
groups applying for the most authorisations, particularly where applications to develop
international networks were managed centrally on behalf of a group of operators.
5.63 We therefore caution that authorisations may have been applied for at “either end” of the
international route in question, and might be applied for in different Member States in
different years. This means that changes in where operators seek authorisations might cause
apparent but illusory shifts in demand between Member States. This issue could be resolved if
authorisations were reported by Member State pair, rather than by the Member State issuing
the authorisation.
5.64 Even so, the destination of a coach route may not be the destination of the passengers, who
may either alight in an intermediate country or continue to a further country, whether with
the same or another coach operator. For example, if it is required by the relevant Member
States, a coach operator may have authorisation to operate services in States A-B-C and in
States C-D, but may carry a significant proportion of its passengers between A and B, B and C,
A and D and B and D, none of which will be listed as authorised services.
5.65 We also caution that only a small proportion of the valid authorisations may actually be in use.
For example:
In Greece, one stakeholder expressed the opinion that many more authorisations had
been issued for some routes than could profitably be operated in the market, particularly
given the current economic crisis. At the end of 2014 there were 15 valid authorisations
from Greece but 52 valid authorisations to Greece.
In Sweden, there are 13 valid authorisations from Sweden and 137 valid authorisations to
Sweden, but national statistics report that at the end of 2013 there are only seven
international routes (see Appendix A, Table A.42).
Interpreting current reporting requirements
5.66 A number of factors limit the value of the number of Community licences and authorisations
as an indicator of the size of either the domestic or the international market:
Community licences and certified true copies may not have been used for up to ten years.
Member States may, but are not required to, accept Community licences for national
transport operations.
Authorisations, which are valid for five years, may not have been used at all during this
period.
Authorisations are not required for either occasional international services or special
regular international services covered by a contract between organiser and carrier.
Control documents may be simplified or abolished by agreement between Member
States.
The same operations and journeys may be reported in different Member States in
different years, depending on the Member State in which Community licences, certified
true copies and authorisations are sought. Without these control documents being
identified to a particular Member State pair, this means that data on the volumes of
control documents can only be interpreted with confidence for the EU as a whole.
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5.67 The cumulative effect, as the above analysis shows, is that information reported under Article
28 of Regulation 1073/2009 to the Commission may not be meaningful at the national level
and indicate:
permissions granted in the past (whether Community licences, certified true copies, or
authorisations); rather than
services operated in the present.
5.68 We discuss further in Chapter 8 the scope for gathering information which more closely
reflects activity in the international coach market.
Authorisations for cabotage
5.69 Only a small number of authorisations for cabotage on regular international services were
reported during 2014, as shown in Table 5.6. This may be partly because Article 15 of
Regulation 1073/2009 authorises cabotage operations for regular services performed in the
course of a regular international service which has already being authorised.
Table 5.6: Authorisations for cabotage by regular services (2014)
Source: Member States’ returns to the Commission under Regulation 1073/2009 Article 28(2).
5.70 The Commission received only one report of cabotage during special regular services and only
a few reports of cabotage during occasional services. This may be at least partly because
Article 15 authorises cabotage operations for special regular services and occasional services
and there is no requirement for operators to apply for authorisation to conduct cabotage
operations for these types of service.
5.71 In addition, Member States which have liberalised some or all of their domestic markets may
implicitly or explicitly have permitted cabotage as part of the process. However, liberalisation
does not appear to have eliminated completely the need for authorisations in the Member
States listed in Table 5.6.
5.72 We also note that many international coach services, like international air services, operate
non-stop between origin and destination, and adjust vehicle size and service frequency to
ensure an adequate load factor, if necessary providing connections between “thick” and “thin”
sections of route at a number of hub terminals. There may therefore only rarely be a
commercial benefit in stopping international services en route to accept cabotage passengers.
5.73 Finally, while there are a small but significant number of very long-distance coach routes
across Europe, as illustrated in the case studies earlier in this chapter, a large number of
international coach journeys may only enter two or three Member States. Over half the
Member States have two or fewer land borders with other Member States, seven have only
one land border and two, the islands of Cyprus and Malta, have none. Particularly for Member
States with only one land border, such as Greece, Portugal, Ireland and the United Kingdom, it
may have been simple or sufficient to liberalise services bilaterally in advance of Regulation
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1073/2009. We note, for example, that Sweden and Finland, which share a short stretch of
border more than 600 kilometres away from either of their capital cities, signed an agreement
in 2003, including Denmark and Norway, abolishing journey forms for international occasional
services.
5.74 In summary it is possible that:
Cabotage on services already authorised is also automatically authorised under Article 15.
Cabotage occurs mainly within adjacent Member States or groups of Member States
which have liberalised more than Regulation 1073/2009 requires (as is permitted by
Article 25), and is not reported under these more liberalised regimes.
Cabotage is implicitly or explicitly permitted by domestic liberalisation in some Member
States.
Cabotage is rarely the most commercially effective means of providing for both
international and domestic passengers.
International coach operations
5.75 Given the limited scope to identify changes in international coach markets from Member
States’ returns under Article 28, we also gathered information from those Member States who
reported data on the scale of the international coach markets. As we noted in Chapter 2,
Member States report a variety of information on a range of different, and mutually
inconsistent bases.
5.76 We discuss in turn below our findings on quantitative data on international coach routes,
international coach passengers, and international coach passenger-kilometres.
International coach routes
5.77 Seven Member States collate or publish lists of the number of coach services entering, passing
through or leaving their territories, which we summarise in Table 5.7.
Table 5.7: International coach routes identified by Member States
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5.78 We only found data for more than one year for three Member States, Poland, Sweden and
Slovenia. As with domestic services (see paragraph 4.15), the definition of a “route” may vary
between Member States.
5.79 The small number of routes reported in Sweden has declined. This may be related to the
increased number of authorisations (Figure 5.8) and certified true copies (Figure 5.7) issued in
Denmark, for example if operators of services between the two Member States are
increasingly based in Denmark.
5.80 The slightly more numerous routes reported in Slovenia have risen from 26 to 29 and then
fallen back to 25, although we note that these are referred to as bus routes.
5.81 The most substantial change appears to be in Poland, where the number of routes reported
fell from 111 to 90 in a year. This may be related to the rapid expansion of Lux Express and
other operators through Poland, although it is not clear why this would result in a fall in the
number of routes. It may reflect the expiry of authorisations issued around 2009, or a shift to
services described in the Baltic Corridor case study being documented in Estonia. As Figure 5.2
shows, Lux Express now operates services from Estonia through Latvia, Lithuania, Poland and
Slovakia to Hungary, which might in principle have authorisation issued in Estonia or any other
of these Member States.
International coach passengers
5.82 While only seven Member States report the number of international coach routes, as shown in
Table 5.7, ten publish data on international coach passengers, which we summarise in Table
5.8.
Table 5.8: International coach passengers (2009-2014)
Passengers Regular or occasional 2009 2010 2011 2012 2013 2014 Average
(thousand) percentage
annual
change
Croatia Regular and occasional 2,466 2,100 2,347 2,205 1,612 -10%
Czech Republic Regular only 1,212 1,130 1,598 1,980 1,981 2,088 12%
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Passenger numbers may be counted more than once (a journey from A via B and C to D
may be counted in up to four Member States, or as a departure in up to three of them).
Consolidation in the market, through merger between operators (such as that between
FlixBus and MeinFernbus), may affect the number of times an individual passenger is
ticketed or reported, potentially complicating any interpretation of time-series data.
5.84 Nevertheless, the table indicates substantial annual growth in international passengers in a
number of Member States, notably the Czech republic, Estonia and Poland. The growth in
Estonia may reflect the expansion in services operated on the Baltic corridor in recent years.
However the growth rate of 17% in Poland is based on comparison of only two years’ data,
and is superficially inconsistent with the fall in the number of routes reported in Table 5.7.
International coach passenger-kilometres
5.85 Ten Member States also report estimates of passenger-kilometres, which we summarise in
Table 5.9.
Table 5.9: International coach volumes (2009-2014)
Passenger- Regular or occasional 2009 2010 2011 2012 2013 2014 Average
kilometres percentage
(million) annual
change
Croatia Regular and occasional 536 500 519 505 485 -3%
Czech Republic Regular 744 777 978 908 1,066 1,080 8%
Estonia Regular 128 156 213 255 302 343 22%
Occasional 244 296 256 261 312 192 -5%
Italy Regular 1,254
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Member States identified in Table 5.8, with growth in Estonia and Poland being similarly
strong.
Estimates of market characteristics
5.88 We examined the extent to which the Member States’ data in Table 5.8 and Table 5.9 could be
used to examine trends in the international coach market. After review of the data for
inconsistent or implausible values, we concluded that it would be possible to make the
following estimates:
average 2014 international trip lengths reported by four Member States: Portugal, the
Czech Republic, Estonia and Lithuania;
average 2009-2014 growth in international regular services for six Member States:
Estonia, the Czech Republic, Lithuania, Portugal, Slovenia and the Netherlands; and
average 2009-2014 growth in international occasional services for three Member States:
Estonia, Portugal and the Netherlands.
Estimates of trip lengths
5.89 Our findings on average trip lengths are shown in Figure 4.2.
Figure 5.10: International coach travel: estimated average trip length
Source: Steer Davies Gleave analysis of Member States’ data and additional assumptions for missing years.
Note: data may be affected by the same services being reported in a different Member State in 2009 and 2014.
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5.90 Data from Portugal in Table 5.8 and Table 5.9 imply that the average international trip length
in 2014 was around 1,250 kilometres on regular services14 and around 800 kilometres on
occasional services15. The other Member States’ data imply shorter average trip lengths in the
range 250-500 kilometres on regular services and also, in the case of Estonia, on occasional
services.
Estimates of growth in international regular services
5.91 Figure 5.11 shows our estimates of the growth in international regular services, in either
reported passenger journeys or estimated passenger-kilometres.
Figure 5.11: International regular services: growth in reported passengers (2009-2014)
Source: Steer Davies Gleave analysis of Member States’ data and additional assumptions for missing years.
Note: data may be affected by the same services being reported in a different Member State in 2009 and 2014.
5.92 With the exception of Slovenia, all the Member States’ data suggest that there was
considerable growth in international passenger journeys between 2009 and 2014. In the case
of Estonia, the reported number of international journeys (however counted) doubled from
1,100 to 2,200 per day. However, while estimated passenger-kilometres reported in Estonia
and Lithuania grew more than reported passenger journeys, in the other Member States the
opposite was the case, implying that the average length of international trips fell over the
period.
14
This is approximately the distance from Lisbon to Barcelona, and is only plausible if many passengers
on regular international services to and from Lisbon crossed Spain completely and continue into France
and beyond. The data suggest that this distance has fallen from over 1,400 kilometres in 2010 and 2011.
15
This is further than the distance to Madrid, and in 2013 the implied average distance was over 1,000
kilometres.
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5.93 Adding data from the six Member States together, the reported number of passenger trips
increased by 56%, and the estimated passenger-kilometres rose by 31%. Note, however, that
these data are dominated by the Czech Republic, which contributed more than half the total.
5.94 Figure 5.12 shows our estimates of the growth in international occasional services, in either
reported passenger journeys or estimated passenger-kilometres.
Figure 5.12: International occasional services: growth in reported passengers (2009-2014)
Source: Steer Davies Gleave analysis of Member States’ data and additional assumptions for missing years.
Note: data may be affected by the same services being reported in a different Member State in 2009 and 2014.
5.95 Member States’ data on international occasional travel imply a growth of around 25% over the
period 2009 to 2014. However, while Estonia and the Netherlands, which dominates the
reported volume, reported a fall in estimated passenger-kilometres, Portugal reported a rise.
We stress that this may result from effects such as changes in the Member State in which
services were reported.
Estimates of international market growth
5.96 The data series on passenger numbers and passenger-kilometres collated in Table 5.8 and
Table 5.9 cover over only some years for some sectors for some Member States. However, we
used them to estimate indicative rates of growth over the period 2009 to 2014 (as we did with
partial employment data to create Figure 3.8).
5.97 The resulting estimates of the patterns of growth are shown in Figure 5.13 and Figure 5.14
below.
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Source: Steer Davies Gleave analysis of data from national statistical departments, see text for details.
Source: Steer Davies Gleave analysis of data from national statistical departments, see text for details.
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5.98 Figure 5.13 suggests that passenger numbers fell slightly in 2010 before growing until 2014.
Depending on the extent to which markets with only limited data are included in the
estimation process, the overall growth since 2009 or 2010 appears to be in the range 50±10%.
5.99 Figure 5.14 suggests that passenger-kilometres have risen slowly since 2009. Depending on
the extent to which markets with only few data points are included in the estimation process,
the overall growth since 2009 appears to be in the range 20±20%.
5.100 We conclude that while there may have been a decline in international coach travel in 2010,
there has been at least some growth since then, although the higher rise in reported
passenger journeys than estimated passenger-kilometres suggests that average trip lengths
have been falling.
Estimates of international market size
5.101 Comparing Table 5.8 and Table 5.9, it can be seen that only eleven Member States either
report international passenger volumes or estimate international passenger-kilometres. These
do not include the large Member States of Germany, Spain, France and the United Kingdom.
5.102 In addition, as we indicated in paragraph 2.6, international bus and coach vehicle-kilometres
and passenger-kilometres are reported in different, and mutually inconsistent, ways by
different Member States. This means that reports of international travel by the Member States
are neither exclusive nor exhaustive:
Data are not exhaustive where each Member State only reports travel in its territory, or of
operators registered in it.
Data are not exclusive where both Member States A and Member State B report
passengers travelling from A via B to C.
5.103 Data reported by individual Member States may, if reported on a consistent basis each year,
be a guide to changes over time16. However, it is not possible either to combine data from
Member States or to use data from one Member State to estimate data for another Member
State.
5.104 Table 5.8 and Table 5.9 suggest a 2014 market, in ten or eleven mainly small Member States,
of approximately 10 million passenger trips and 23 billion passenger-kilometres. The EU-wide
market is likely to be several times larger.
5.105 Note that our 2009 report did not include disaggregated data for international markets.
However, the data reported in Figure 5.13 and Figure 5.14 indicate significant growth since at
least 2010, suggesting that operators in a number of Member States have begun to exploit
new market opportunities following the liberalisation of international services enabled by the
Regulation.
International coach fares
5.106 Many data on average coach fares in some Member States combine both domestic and
international markets, as we discussed in Chapter 2.
16
In practice, this is not the case. Sweden’s data appears to be based on an average international trip
length of 252 kilometres from 2009 to 2011 and 207 kilometres in 2013. Both average distances appear
small, given that the Swedish coach network radiates from Stockholm, which is 360 kilometres from the
nearest land border.
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5.107 Consistent data on international fares are more difficult to collect, for a number of reasons:
There are 756 combinations of pairs of Member State (fares may differ by direction),
although in practice fares are not offered between all possible Member State pairs.
Member States may collect data on domestic or total transport volumes and revenues,
allowing the estimation of an average yield per passenger or per passenger-kilometre,
but, as noted in paragraph 2.6, do not identify international transport on any consistent
basis.
Where international coach routes are new, following liberalisation at either European or
domestic level, there may be no time series of fares data, and initial fares may be low to
attract new customers and to make maximum use of committed capacity.
5.108 Nonetheless, for a sample of international coach services, listed in Table 5.10, we identified
the lowest available fare by coach and rail for travel on the day and one week and one month
ahead. The table sorts the resulting fares in descending order of the ratio of coach to rail fare.
Table 5.10: Cheapest fares for international coach and rail journeys
Note that quoted fares from the destination may Cheapest single or return Coach fare
differ from those from the origin fare per kilometre as
Rail quality
percentage
Origin Destination Coach Rail of rail fare
RO Timisoara HU Budapest Slow €0.32 €0.06 561%
BG Sofia EL Thessaloniki Slow €0.17 €0.09 205%
PL Poznań DE Berlin Slow €0.15 €0.08 187%
SK Bratislava CZ Prague Slow €0.05 €0.03 175%
SE Stockholm NO Oslo €0.08 €0.05 164%
CZ Prague AT Vienna €0.07 €0.07 131%
ES Barcelona FR Marseille €0.14 €0.13 105%
IT Milan CH Geneva €0.10 €0.11 86%
DE Berlin PL Warsaw €0.03 €0.05 68%
IE Dublin UK Belfast €0.07 €0.12 56%
FI Helsinki RU Sankt Peterburg €0.02 €0.04 55%
FR Paris DE Frankfurt High speed €0.04 €0.08 46%
FR Paris UK London High speed €0.06 €0.14 46%
AT Vienna DE Nürnberg €0.06 €0.14 44%
DK Copenhagen SE Göteborg €0.07 €0.17 40%
BE Brussels FR Paris High speed €0.06 €0.22 28%
UK London DE Köln High speed €0.03 €0.13 26%
NO Oslo NO Göteborg €0.05 €0.21 22%
BE Brussels UK London High speed €0.06 €0.30 19%
Source: Steer Davies Gleave analysis of on the day, and week and month ahead coach and rail fares 2015-2016.
5.109 Figure 5.15 shows the relative fares in the form of a bar chart and Figure 5.16 shows them as a
scatter diagram with rail fare per kilometre on the horizontal axis.
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Figure 5.15: Cheapest fares for international coach and rail journeys
Figure 5.16: Cheapest fares for international coach and rail journeys
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17
High fares for international rail journeys to/from London may, in part, be due to high access charges
for passage through the Channel Tunnel.
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5.119 We note that Regulation 1073/2009 allows operators to apply for Community licences and
particularly authorisations in the most convenient, or easiest, Member State. We also note
that the Danish Transport and Construction Agency, for example, has never refused a request
for international regular services (see Appendix A, A.85).
5.120 However, many of the potential barriers to entry into domestic markets listed in Table 4.10
and paragraph 4.87 may also affect international services, including:
prohibitions on the use of local bus stops for coach services;
lack of facilities for safe loading and unloading at tourist attractions and coach parks;
restrictions in central city tourist areas; and
where coach terminals exist, either lack of capacity at, or difficulties in gaining access to,
them, which we discuss further in Chapter 6.
5.121 Moreover, we consider that the availability of terminals with good quality facilities (such as
well-signed interchanges, and relevant and accessible passenger information) are particularly
important in the case of international services. This is because international passengers are
more likely to be unfamiliar with at least at one end of their journey, and hence to consider a
service that terminates at a location with poor information and/or connections to be
unattractive.
Key findings and conclusions
Findings from case studies
5.122 Coach operators can add and remove routes relatively easily, allowing them to enter markets
on a trial basis, or to modify services rapidly as markets change.
5.123 As with domestic coach services, operators may act in partnerships, groups or alliances if this
enables them to offer a more effective network. Operators may provide, under subcontract,
international or cabotage services in a number of Member States.
5.124 The provision of coach services, and their relative success, will generally depend on the
characteristics of competing modes including car, rail and air. These may change with further
investments in road, rail or airport infrastructure. However, coach is often able to serve more
stopping points than rail or air, because it is not necessarily constrained by the need for
expensive fixed terminals.
5.125 Barriers such as the change of rail gauge, between the Baltic States and Poland, and the Alps,
between France and Italy, can hinder or help coach as a mode. However, even where coach is
slower, less frequent and less comfortable that other modes, its lower costs mean that it can
often remain in the market by offering lower fares, or by not charging for heavy baggage.
5.126 The critical factor to the provision of new international services can be more general domestic
liberalisation in one or more of the Member States involved.
5.127 International coach services and networks can be dynamic, with competition sometimes
leading to price wars and the subsequent withdrawal of one or more operators.
Article 28 reports on control documents
5.128 Article 28 of Regulation 1073/2009 requires the Member States to report on various
documents including Community licences, certified true copies, authorisations and journey
forms (control documents). In practice, this information appears to be of limited value in
monitoring the market, for a number of reasons:
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6 Terminals
Introduction
6.1 Regulation 1073/2009 does not define or refer to “terminals”. Regulation 181/2011, which we
discuss in greater detail in Chapter 7, states that:
“Terminal” means a staffed terminal where according to the specified route a regular service is
scheduled to stop for passengers to board or alight, equipped with facilities such as a check-in
counter, waiting room or ticket office.
6.2 However, Regulation 181/2011 neither requires that such terminals exist, nor requires that
regular services make use of them, nor clarifies whether a terminal can be part of a site,
facility, structure or building defined elsewhere in legislation as, for example, a railway station,
ferry terminal or airport.
6.3 In practice, many coach services serve points without check-in counters, waiting rooms or
ticket offices. For example, the Danish Transport and Construction Agency pointed out that it
has no standards for terminals: some only provide a place to stop, while others provide
waiting rooms, toilets and ticket offices.
6.4 In this chapter we discuss in turn:
terminals across the EU;
provision, control and regulation of terminals;
ensuring access to existing capacity;
adding or relocating capacity; and
the example of bus and coach services at London’s Heathrow airport, which includes the
UK’s busiest single coach station and illustrates the potentially complexities of terminal
operations, ownership and regulation;
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Designated (PRM)
Member State
Routes and/or
Within 1000
Main/major
central area
Bus or tram
Motorway
metres of
operators
railway
station
Metro
AT Vienna Blaguss 3,700
International
Busterminal (VIB)
BE Brussels Gare du 1,300
Nord
BG Sofia "Централна автогара" АД 1,400
BG Plovdiv Rodopi
BG Plovdiv South Автогара "Юг"
BG Plovdiv North Автогара "Север"
CY Nicosia Solomou 4
Square
CZ Prague Florenc 1,400m 600m
CZ Brno Zvonařka 1,400m 800m
CZ Brno Grand 350m
CZ Ostrava central bus 1,700m Minor
station station
DE Berlin Zentraler 8,000m 200m
Omnibus-bahnhof
(ZOB)
DE Hamburg Zentraler
Omnibus-bahnhof
(ZOB)
DE Hannover Zentraler
Omnibus-bahnhof
(ZOB)
DE Mannheim 1,200m
Zentraler Omnibus-
bahnhof (ZOB)
DE Munich Zentraler 2,500m Minor
Omnibus-bahnhof station
(ZOB)
DK Ingerslevsgade
(on street)
DK Århus 300m
Rutebilstation
EE Tallinn Bussijaam T grupp as 1,600m
EL Athens Kifisos (A) KTEL 3,100m
EL Athens Liosia (B) KTEL 2,900m
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Designated (PRM)
Member State
Routes and/or
Within 1000
Main/major
central area
Bus or tram
Motorway
metres of
operators
railway
station
Metro
EL Thessaloniki KTEL 3,900m
EL Larissa KTEL 1,500
m
ES Madrid Mendez City of Madrid 8 operators 3,200m
Alvaro
FI Helsinki Kamppi 300m
FI Tampere 700m
FR Paris Bercy Ouibus only? 2,800m 300m Minor
station
FR Paris Gallieni Eurolines 4,900m
only?
HR Autobusni Kolodvar Zagrebački Holding d.o.o. 1,500m 1000m
Zagreb
HU Budapest Népliget 4,300m 850m
IE Dublin Busáras Córas Iompair Éireann (CIÉ)
IT Bologna Municipality and City 81 operators 200m
Autostazione
LT Vilnius 166 1,900m 400m
LT Kaunas Kautra 113 1,200m
LT Klaipėda 2,000m
LT Šiauliai Busturas 700m
LT Panevėžys
LU Luxembourg Gare
Routière
LV Riga International Rīgas starptautiskā autoosta 350m
Coach Terminal
MT Valletta Bus only, no
coach network
NL Amsterdam 2 (Ouibus, 4,300m
Sloterdijk MeinFernbus)
PL Warszawa 3,600m
Zachodnia
PL Krakow
PT Sete Rios 3,000m 800m
RO Bucharest Filaret 22 operators 1,500m 300m
RO Timisoara Autotim Autogara Autotim S.A 16 operators 2,400m 500m
SE Stockholm Storstockholms Lokaltrafik
SE Jönköping
SE Umeå 50m
SE Luleå 150m
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Designated (PRM)
Member State
Routes and/or
Within 1000
Main/major
central area
Bus or tram
Motorway
metres of
operators
railway
station
Metro
SI Avtobusna postaja
Ljubljana
SK Bratislava Mlynské 1,500m
Nivy
UK London Heathrow Heathrow Airport Limited N/A Airport
Central Bus Station station
UK London Heathrow Heathrow Airport Limited N/A Airport
Terminal 4 station
UK London Heathrow Heathrow Airport Limited N/A Airport
Terminal 5 station
UK London Victoria Transport for London 2,200m 500m 300m
UK Birmingham National Express 500m
UK Belfast Europa Translink
Source: Steer Davies Gleave analysis, note that terminals are not systematically provided in some Member States.
Note: terminals are illustrative and may not be representative or the most important in the Member State or city.
Note: “Designated (PRM)” refers to whether a terminal is designated under Article 12 of Regulation 181/2011.
6.6 We sought information on the number of passengers or services using terminals, or the
effective number of stands or gates, to enable us to identify their relative sizes and
importance, but in practice this information was rarely available. In Germany, for example, the
Ministry of Transport and Digital Infrastructure (BMVI) stated that 43 terminals had been
identified, but these could not be ranked in importance because exact passenger numbers
were not available.
6.7 Nonetheless, Table 6.1 enabled us to identify wide variations in a number of areas:
location and accessibility to other public transport; and
direct access to the long-distance motorway network.
6.8 Table 6.2 groups some of the terminals listed in Table 6.1 according to their location in the
urban area. While this analysis is limited, it illustrates some of the patterns of provision and
the issues faced in locating, relocating, or duplicating terminal capacity.
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6.9 Some coach terminals are also the local urban and suburban bus stations, and all the coach
terminals we examined had at least some local bus services, although these might not be a
major node on the local bus network, as is the case in Luleå. In practice, as we noted in
Chapter 2, and can be seen from the example of Heathrow Airport in Table 6.5, the distinction
between buses and coaches is not always clear, especially when different types of vehicle are
used on the same services.
6.10 Connections to rail services are more variable, particularly where rail and bus were seen as
competing, rather than complementary modes. Even in cities where metros exist, coach
terminals do not always have good access to them, as in Athens and London.
At main railway stations
6.11 Many terminals are collocated with the main railway station, which is often in the city centre
and within walking distance of activities such as offices, shops and hotels. This is likely to occur
where the national rail operator is also a coach operator. However, even railway stations not
in the centre are likely to provide connectivity through taxi, bus, any local rail services and, in
larger cities, tram or metro. If the national rail operator owns or manages the railway station
terminal, it may be in a position to abuse its market power.
Elsewhere in the city centre
6.12 Some cities, including some with few if any railway services, have a coach terminal, typically
also the bus terminal, in the city centre. The terminal therefore provides a combination of
coach, bus and taxi services and a central location.
6.13 In the UK, London’s main coach terminal at Victoria Coach Station is several hundred metres
from the nearest Underground (metro) and railway stations and nine kilometres from the
nearest grade separated route out of London. In practice, however, the size of cities such as
London, Berlin and Paris makes it difficult to identify one ideal location for a coach terminal.
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Regional authority
National transport
National authority
Sector regulator
Terminal
Coach operator
Local transport
Local authority
Bus stops used
Local planning
Other private
or MS
National law
Designated
authority
authority
authority
Railway
Heathrow
AT 1 Mix
BE 1 Yes
BG 2 Mix
CY 16 Mix
CZ 7
DE 2
DK 1
EE 1 Mix
EL 26
ES 4 Mix
FI 13
FR 11 Mix
HR 3
HU 28
IE 4
IT 1
LT 9
LU 1
LV 1 Mix
MT 0 N/A
NL 1
PL 1
PT 6
RO 87
SE 3 Mix
SI 1 Mix
SK 12 Mix
UK 3 Mix
6.19 We discuss in turn below the variations in terminal provision, ownership, which in some cases
is by operators, and regulation.
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Provision
6.20 Provision of terminals is variable:
Some Member States appear to expect or require the competent national, regional or
local authorities to provide bus and coach terminals.
Others, such as Belgium and France, have no systematic provision of terminals.
6.21 We also attempted to identify which terminals had enclosed waiting areas, but found little
information and a wide range of different levels of protection from the elements. The latter
possibly reflects different attitudes to protection from the weather, which appear to depend
on variations in local expectations and particularly in climate:
In Sweden, many terminals provided heated waiting space with gates direct to the coach
stands and, in the case of Jönköping, the collocated railway platform (although we note
that Jönköping is not designated under Article 12 of Regulation 181/2011).
In Cyprus, Nicosia’s terminal is designated under Article 12 of Regulation 181/2011, but
we have not been able to confirm the existence of any facilities other than shade from
heat and rain.
6.22 There is also wide variation within Member States:
In Denmark, the Århus Rutebilstation has been designated under Article 12 of Regulation
181/2011. However, the Danish Transport and Construction Agency informed us that
some operators choose to stop elsewhere, apparently to avoid the fees for its use. There
is no terminal in the capital, Copenhagen, where the main stopping point appears to be
on-street, near the main station.
In Greece, 26 terminals have been designated, but these do not include either of the KTEL
terminals in the capital and largest city, Athens.
In Finland, Helsinki has a relatively new underground coach terminal with 35 gates, but
Tampere, the third largest city, has a recently-restored coach station dating from 1938.
6.23 Finally, there is also wide variation within individual cities:
In Bulgaria, Plovdiv’s designated Rodopi terminal is close to the South terminal (Автогара
"Юг") which is not designated.
In the Czech Republic, Brno has both a designated terminal at Zvonařka and an on-street
terminal outside the Grand Hotel, which is more convenient for the city centre.
Ownership
6.24 A variety of ownership models exist, including ownership by national, regional and local
government, by operators, by the railway infrastructure manager, by an airport (in the case of
London Heathrow and other airports), or privately by other parties. The Danish Transport and
Construction Agency, for example, reported that some coaches use ferry terminals. We note
that the owner of the terminal might not be the operator, particularly where the terminal is
part of a multi-function complex including other activities such as a shopping centre, as in
Helsinki Kamppi and Stockholm Cityterminalen.
Regulation
6.25 One major issue of regulation is the extent to which coach operators are required either to use
a terminal specified by the competent authorities or, in some cases, to procure or provide
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their own, or are permitted to use on-street bus stops. Considering the use of on-street bus
stops:
In the Netherlands, this is not permitted.
In France, this may be the only option available to operators other than SNCF.
In Belgium, this is normally the only option available to any operator.
In Sweden and the UK, this may be an integral part of the service offer, as in the case of
Flygbussarna (see Appendix A, Figure A32) and the Oxford Tube (see Appendix A, A.377).
6.26 In some cases terminal owners or managers publish access conditions and prices, but we have
not attempted to investigate the exact details because:
The terms and conditions of access to individual terminals may vary from terminal to
terminal, even within a single city or a “campus” such as Heathrow.
The terms and conditions for use of on-street bus stops, if permitted at all, may vary
between competent authorities.
6.27 Use of terminals by operators may also be either obligatory, such as where coach services are
not permitted to call at local bus stops, or commercially necessary, to attract passengers.
However, as we noted in Table 4.10, stakeholders in a number of Member States reported
difficulties of access to terminals. We discuss in turn below:
Ensuring access to existing capacity, which stakeholders reported could be or had been
restricted in Austria, the Czech Republic, France, Croatia and the UK.
Expanding capacity at terminals where allocation is on a transparent and non-
discriminatory basis, but there is no longer any spare capacity, as at Stockholm’s
Cityterminalen and London’s Victoria Coach Station.
Terminals: ensuring access to existing capacity
6.28 Access to terminals may be managed on a number of different bases, which we illustrate in
Table 6.4 and discuss further below.
Table 6.4: Terminals: approaches to managing access
Allocation of Allocation of
Vertical Quantity
Member State Exclusive rights stands to time slots to
integration licensing
operators operator
KTEL
EL Greece
cooperatives
PL Poland Most terminals
SE Sweden Cityterminalen Cityterminalen
Victoria Coach
UK UK Heathrow Heathrow
Station
6.29 Note that we did not identify any specific examples of allocation of capacity by an
independent or neutral regulatory body, as is often required in the allocation of airport slots
and is mandated for railways by Article 7 of Directive 2012/34.
Vertical integration
6.30 Vertical integration between a terminal and an operator is possible, and this may result in
discrimination against, or exclusion of, other operators, whether space is available or not.
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In Spain, our 2009 study identified a serious case of illegal abuse of a dominant position by
a vertically integrated terminal operator18. However, of the stakeholders in Spain
contacted in the current study, neither the Public Administration, nor associations of bus
operators and terminals operators, nor the operators themselves, identified
discriminatory barriers to entry to terminals (see Appendix A, A.127).
In Poland, our 2009 study noted that virtually all terminals are owned and managed by
the dominant bus operators, the PKS/PPKS companies, and there had been complaints of
discriminatory treatment by other operators19. However, none of the stakeholders
contacted in the current study reported any discriminatory barriers to entry.
Exclusive rights
6.31 Another approach to allocation of capacity is to grant exclusive rights to one or more
operators, which could in principle occur through a concession arrangement.
6.32 One example of exclusive rights is found at Heathrow, where the many hotels in the airport
originally each provided their own shuttle bus service. With 29 recognised airport hotels
requiring connections to four terminals in three locations, this resulted in a profusion of
different buses operating in different liveries to different timetables.
6.33 This has now been replaced by the “Heathrow Hoppa” service, under which National Express
operates 28 routes between the terminals and the hotels, as shown in Figure 6.1 below.
18
“Study of passenger transport by coach”, 1.22
19
“Study of passenger transport by coach”, 1.21
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6.34 While this is arguably an example of regulation, rather than liberalisation, our assessment of
the consolidated access arrangements is that it may bring a number of advantages:
For the airport, it reduces volumes of traffic and the need for coach stands, and results in
a single operator responsible for all hotel services.
For the operator, it offers better load factors (hotels in the same direction combined into
a route), and scope to manage the fleet to prioritise passengers waiting at hotels for
departing flights.
For the passengers, it provides a consistent brand, location, price and standard of service
(some or all of which may be controlled or incentivised by the airport).
For the hotels, there is no need to own, procure, manage or staff a dedicated bus service.
6.35 In contrast, Heathrow has relatively few car hire companies, each of which may generate
sufficient demand to fill its own dedicated and branded service, and to take responsibility for
any delays to its customers, and these continue to operate independently.
6.36 This suggests that exclusive rights to use a coach terminal may be advantageous for
passengers, operators, terminal owner and other parties, at least in specific circumstances.
Quantity licensing
6.37 Our 2009 study noted that quantity licensing was used in Greece to limit the number of
operators on each route, and that this also had the effect of managing demand to be within
the capacity of the terminals20.
6.38 Quantity licensing could in principle also be applied to terminals directly as a means of
managing demand, for example by a planning authority or terminal manager wishing to limit
the overall levels of traffic at a coach terminal on a non-discriminatory basis. In principle it
would be possible to issue permits to call at the terminal, and to allow these to expire, be
returned, be exchanged or be traded on a secondary market. However, we note that some of
these mechanisms could result in a dominant operator exploiting its position to exclude
potential competitors.
Allocation of stands to operators
6.39 At terminals where capacity is not highly constrained it may be practicable to dedicate one or
more stands or gates to each operator, as illustrated in Figure 6.2.
Figure 6.2: Sweden: bus terminal gate dedicated to an operator
20
“Study of passenger transport by coach”, 6.19
6.40 This shows a gate at a terminal dedicated to an operator specialising in airport coach services.
Focusing these services on a specific gate allows associated facilities such as the operator’s
ticket machines and airline check-in machines to be collocated, and minimises the need for
airlines passengers with baggage to move between gates.
6.41 Allocation of stands to operators also forces the operators to internalise any conflicts within
their own scheduling and can incentivise them to arrange their timetables so that their
services can be provided with the minimum total number of stands. However:
It can still be relatively inefficient at terminals served by many small operators, none of
which requires a stand at all times.
It does not in itself help manage peaks in arriving and departing traffic, which our 2009
study noted had been an issue at Victoria Coach Station21.
If even the smallest operator must pay for a stand, rather than (say) pay a tariff per coach
movement, the charges could be seen as discriminatory against small operators.
Allocation of time slots to operators
6.42 An alternative approach to the allocation of terminal capacity is to allocate time slots to
operators. This approach is used at Cityterminalen in Stockholm and Victoria Coach Station in
London.
6.43 For example, an operator with a 12:00 departure might be allocated a stand which they were
entitled to occupy for 30 minutes, illustratively from 11:35 to 12:05, but which might be used
immediately beforehand or afterwards by a different operator. Arriving coaches might use a
common drop-off area, which they may need to occupy for a few minutes while passengers
and baggage are unloaded. However, if the coach scheduled to take the 12:00 service were
scheduled to arrive at 11:40, but actually arrived at 11:20, it might have to leave the terminal
and wait elsewhere until its stand became available. This could create an issue of where
coaches should or may wait for the variable period between their actual arrival time and their
scheduled departure time. Under these circumstances it would appear sensible to have
mechanisms whereby the operator could enter its allocated stand early, provided that it was
available.
6.44 Allocation of time slots to operators has the potential to make more efficient use of
constrained terminal space. In our 2009 study, we noted that Cityterminalen was considering
reducing the time slots from 30 minutes to 15 minutes to increase effective capacity22. It has
now standardised on windows of 5 minutes on arrival and 15 minutes at departure, with an
additional discount for “quick loading” departures with a maximum time of 5 minutes.
However, unless operators have dedicated gates, there may be limited scope for them to
customise their service or to collocate facilities such as ticket desks and machines or
information relevant to their services.
6.45 In practice, it may in any case be most effective for terminal managers to give large operators
a number of dedicated stands, within which the operator itself can manage out-of-time
arrivals and departures without interfering with other operators. However we identified a
number of potential difficulties with allocation of time slots:
21
“Study of passenger transport by coach”, 6.10
22
“Study of passenger transport by coach”, 6.10
Operators of short distance services, or those with reliable journey times, might be able to
operate reliably with shorter slots. Imposition of a fixed 30 minute slot for all operators
might be seen as imposing a cross-subsidy from operators with reliable journey times and
rapid turnarounds to operators with unreliable journey times and slow turnarounds.
Allowing large operators to have dedicated stands, and to pay by the stand rather than by
the slot or coach movement, might allow them to operate with shorter average time on
stand, but might be seen as forcing cross-subsidy from small operators to large operators.
More widely the standard slot duration, or the relative charges for slots and stands, might
be manipulated to enable effective discrimination between operators.
6.46 In addition, at terminals offering volume discounts, allocation of time slots does not in itself
result in equal treatment between small and large operators. Stockholm’s Cityterminalen, for
example, offers volume discounts of up to 70% on the rates paid by the smallest users.
Grandfather rights to slots
6.47 Capacity at other terminals may be allocated on the basis of “grandfather rights”, whereby
existing operators are entitled to continue to operate their services, subject to some means of
defining what minimum change, such as to timing, calling pattern or final destination,
constitutes a new services. Grandfather rights are recognised in the allocation of airport
capacity, where they may in principle be open-ended, with an existing operator effectively
permitted to operate in perpetuity. Pre-existing access agreements are honoured in the
allocation of railway capacity, although the maximum permitted length of a “framework
agreement” is 22½ years23, consisting of 15 years followed by a 50% extension. In contrast, at
some terminals operators must reapply for terminal slots each year, a non-discriminatory
approach which allows new operators an opportunity to obtain capacity.
6.48 In summary, while there are precedents for grandfather rights not only at coach terminals but
also at airports and on the railway network, once capacity becomes constrained their effect
may be to favour incumbents and potentially to exclude new entrants.
Trading of terminal capacity
6.49 On railways, capacity at terminals and capacity between them cannot readily be separated, so
any railway operator requires a series of contiguous “diagrams”, schedules by which their
trains can operate around the network, including making calls at station platforms, in a way
which is both operationally efficient and commercially attractive. Trading of rail capacity is
explicitly forbidden24:
“Any trading in infrastructure capacity shall be prohibited and shall lead to exclusion from the
further allocation of capacity.”
6.50 In practice, the nature of rail infrastructure capacity is that, once the infrastructure becomes
heavily utilised, direct exchanges of capacity between operators would only be possible if they
provided identical services. Any material change might require the development, under
regulatory supervision, of a wholly new timetable for all operators.
23
Directive 2012/34 Article 42 (6)
24
Directive 2012/34 Article 38 (1)
6.51 Trading of airport slots between airlines is not formally permitted in European law. However,
exchanging slots between airlines is permitted, with the effect that de facto trading takes
place by two airlines exchanging a worthless slot for a valued one in exchange for a payment
not formally recorded as being related to the transaction. Trading can be broadly effective as a
means of enabling airlines to acquire the arrival and departure slots they require to introduce
new services at a congested airport.
6.52 We did not identify any evidence of capacity at any coach terminals being the subject of
trading, or of independent capacity allocation by the infrastructure owner, by a committee of
operators, or by regulation. However, we note that the creation of a formal regulatory
framework for the allocation and pricing of capacity at coach terminals might be complex and
expensive.
Terminals: adding or relocating capacity
6.53 Subject to the issues of allocation of capacity discussed above, many terminals appear to have
adequate capacity for current services, particularly if they were built at times when car
ownership was lower.
6.54 This is not always the case, however, and as we noted in paragraph 4.69, in Germany, Sweden
and the UK, there were observations that terminals with non-discriminatory access criteria
were now having to exclude operators through lack of capacity. More generally, where
demand is increasing, particularly after liberalisation, there may be a need either to expand
existing terminals or to relocate from a small terminal to a large one. Where use of on-street
bus stops is not permitted or inappropriate given the service offer, liberalisation may also
create a need to build a new terminal for as yet wholly unproven demand.
6.55 The experience of deregulation in Great Britain was that a number of operators rushed to
create “terminals” on vacant land, with limited or no passenger facilities. An example is shown
in Figure 6.3 overleaf.
6.56 Stakeholders in Germany have reported that the rapid growth of services since liberalisation in
January 2013 has exposed both a shortage of terminals and a shortage of capacity at existing
terminals. One commented that many of the services emerging are unable to serve city centre
locations.
6.57 However, locating suitable sites for new terminals and obtaining funding and planning
permission, followed by any necessary site clearance, construction and commissioning, may be
time-consuming or problematic. We note in Appendix A (A.67) that a planned new central
terminal in Athens at Elleonas, integrated with the metro system, is projected to cost over €50
million, and it is not clear whether and when it will proceed.
Figure 6.3: United Kingdom: improvised London coach station after 1985 deregulation
6.59 Many city centres have coach terminals, but long-distance travel is often dominated by rail
services from the central railway station. In contrast, many airports have no rail connections
and are reliant on bus or coach services for almost all surface access by passengers and
workers. In addition, air travel is growing rapidly, with the effect that some of the busiest
coach terminals are now at airports.
6.60 Heathrow is Europe’s busiest passenger airport, handling 73.4 million passengers in 2014.
Despite also having rail and metro (Underground) connections, its Central bus station is the
UK’s busiest single coach station, with 1,600 services a day to over 1,000 destinations,
including 500 by coach. However, Terminals 4 and 5, which are outside the central area of the
airport, are also served by a number of long-distance coach services, and each terminal also
has a range of local bus and coach services.
6.61 The range of services includes not only long-distance coach services, such as between central
London and the airport terminals, which are wholly liberalised, but also PSO local bus services
operating within the regulated environment within London, and deregulated non-PSO local
bus services operating between the airport and points outside London. In addition, a range of
shuttle services (not necessarily as originally defined in Regulation 684/92) are provided to
connect the terminals to airport staff car parks, airport public car parks and off-airport car park
providers, and to the depots of the major car hire companies. Finally, there is a system of
“Hotel Hoppa” buses to local hotels, which we discuss further below.
6.62 Heathrow is adjacent to the intersection of the M4 and M25, at that point the busiest
motorway in Europe, and highly accessible by road. The presence of so many regular coach
services means that Heathrow coach stations, built to serve airport users and workers, have
also become major hubs for coach-to-coach transfer, enabling coach passengers to make
connections without the need to travel into the congested urban area.
6.63 Heathrow also demonstrates the potential complexities of the regulatory environment within
a Member State. The long-distance coach market, notionally overseen by the Department for
Transport, is liberalised, in principle allowing any operator to provide commercial services.
However, the airport is also subject to economic regulation by the CAA, which licenses the
airport and has powers to control its charges for the use of airport facilities, and to require
some revenues to be used to reduce charges to airlines through a “single till” approach.
Finally, the airport is subject to a number of planning controls, covering not only aviation
activities but also the provision and management of surface access. These may either be
general planning arrangements of the London boroughs directly affected (the airport itself lies
within the London Borough of Hillingdon) or specified as conditions for the operation of the
airport (the airport’s operations are subject to conditions intended to limit local road traffic,
congestion, noise and pollution).
6.64 The regulatory environment at Heathrow is particularly complex, with access to the terminals
being constrained by a mix of national and local law, airport regulation and licence conditions,
planning conditions, and contracts between the airport and its users, which themselves are
subject to competition law. Heathrow’s bus and coach facilities, and the regime which governs
their use, might have been very different if the airport, or the bus terminals within it, were
owned by a national or local authority.
6.65 In addition, Heathrow is only one of six airports in the London area, of which two are within
London and four are outside it. All have different requirements for long-distance and local
coach services, are in different ownership, with different local authorities and different
regulatory regimes. As we discussed in paragraph 4.69, two airports which have refused access
rights to coach operators have been challenged for abuse of dominance.
6.66 The example of Heathrow, and the variety of arrangements for coach terminals at airports
serving the same city in the same Member State, illustrate a number of issues which may be
relevant to the consideration of access to other bus and coach terminals:
There is a potentially wide range of services, from infrequent long-distance services,
through specialised shuttle buses, to local PSO buses, all of which will require access to
the terminal.
There are potential complexities of regulation through a number of different bodies. In
particular, any harmonisation of access to terminals at European level might need to
interact with, or override, a wide range of national, regional and local regulatory,
licensing, planning and contractual arrangements.
6.67 This also raises a potential issue if there were to be further liberalisation of access to routes or
terminals:
If a terminal like Heathrow was excluded from liberalisation, there would be no right to
operate long-distance services to it, potentially even if the airport and a coach operator
came into common ownership.
If a terminal like Heathrow were included in liberalisation, it might no longer be possible
to prevent local business such as hotels from offering their own services, potentially
limiting the ability of the terminal owner, and the local authorities, to manage traffic and
congestion.
6.68 Special regular services may be needed at Heathrow and other airports for workplace
transport, which would require access to facilities in the airport, even if these were not owned
or controlled by the airport operator or by other airport employers.
6.69 Occasional coach transport is mostly carried out on the routes specified by the organisation or
individual that procures the service. In principle, however, operators or travellers might wish
to procure an occasional service to or from an airport as part of an excursion or conference
arrangement.
6.70 In summary, at some locations such as airports, terminals may be used by any or all of regular,
special regular and occasional services. We would expect similar issues to arise at locations
such as railway stations and ferry terminals. We note that each terminal may, in principle,
have different access conditions and regulatory arrangements, all of which international coach
operators seeking access to terminals must comply.
Key findings and conclusions
The flexibility of coaches
6.71 A key competitive advantage of bus and coach modes is that they are extremely flexible and
often require little or no dedicated en route or terminal infrastructure. However, for long-
distance operators whose passengers may require access to local public transport networks or
safe, secure and comfortable facilities for interchange to other coach services, access to
terminals is often important at key nodes on the coach network. In light of this, where access
to terminals is restricted whether through capacity constraints, secondary legislation (such as
low emission zones) or discriminatory practices this is likely to disproportionately impact upon
international operators.
6.72 Railways require a dedicated fixed “en route” infrastructure and also stations at every point at
which passengers may enter and leave the system. While some intermediate stations may be
little more than a raised surface next to the track, plus appropriate signage and lighting,
terminal stations often have only one or two platforms, and the arrival and departure of every
single train needs to be carefully timetabled and coordinated. Railway infrastructure is defined
by a list of items in an Annex to Directive 2012/34, and includes “passenger and goods
platforms, including in passenger stations and freight terminals” and “access way for
passengers and goods, including access by road and access for passengers arriving or
departing on foot”.
6.73 Aircraft have much less requirement for “en route” infrastructure (although in practice large
volumes of airspace are subdivided and controlled) but require substantial “terminals” based
around a runway, often including extensive infrastructure for passengers to arrive, wait, be
processed and leave. Airports are defined by the International Civil Aviation Organization
(ICAO) and the definitions reflected in European and national law.
6.74 Buses and coaches, in contrast, make use of the general highway infrastructure and can pick
up and set down passengers on any suitable surface, whether on the public highway network
or not. None of the many types of bus and coach services listed in Table 2.2 necessarily
requires a special terminal, although the attractiveness, and hence competitiveness of the
service offer may depend on the operator accessing terminal facilities.
6.75 Occasional services may link a wide range of origins and destinations, and our 2009 study
noted that special regular transport is based around the school or workplace concerned, and
does not usually require a coach terminal.
25
Die Nähe zu Stadtzentren sowie eine zufriedenstellende Anbindung an andere Verkehrsträger ist nach
den vorliegenden Meldungen in allen Fällen gegeben. Die Qualität der bereitgestellten Dienste wie
Serviceleistungen für Fahrgäste, aber auch für Buspersonal, ist an den großen Busbahnhöfen meist
gegeben, bei mittleren und kleineren Busbahnhöfen eher nicht.
Source: Flygbussarna
6.80 In the UK, we also identified the 100-kilometre long Oxford Tube (see also Appendix A, A.377).
This links a number of suburban stops in Oxford, via an intermediate stop at a motorway
junction, with a number of suburban stops in London, in under two hours, but does not use a
terminal in London.
6.81 However, the attractiveness of other services can depend on access to terminal facilities
enabling passengers, for example, to interchange, find information on the route to their final
destination and buy refreshments before or after a journey. As we noted in paragraph 6.62,
for example, Heathrow airport is attractive to coach operators partly because it provides an
opportunity for direct coach-to-coach interchange.
The variety of terminals
6.82 At the beginning of this chapter we noted that there is no definition of a coach terminal,
although Regulation 181/2011 states that:
“Terminal” means a staffed terminal where according to the specified route a regular service is
scheduled to stop for passengers to board or alight, equipped with facilities such as a check-in
counter, waiting room or ticket office.
6.83 In practice even terminals which have been designated (see Table 6.3), and hence must be
able to provide assistance, may not have any of these facilities.
6.84 Where terminals are provided, they vary widely in standard between Member States, within
Member States, and even within the same city. The attractiveness of a terminal may depend
not only on the facilities provided, but also on its location relative to demand, to other public
transport services, and to the motorway or major road network along which services are
operated.
6.85 The example of Heathrow airport demonstrates how a single coach terminal may be:
used not only by regular but also by special regular and occasional services;
used by a wide range of operators;
used by, or provide connections between, a wide range of services with different
functions and customer requirements; and
regulated or constrained by a number of bodies in ways which reflect specific local
circumstances.
Terminal pricing and access
6.86 As we noted in paragraph 6.26, some terminal owners or managers publish access conditions
and prices, but we have not attempted to investigate the exact details, because the terms and
conditions of access to individual terminals may vary from terminal to terminal, even within a
single city or a “campus” such as Heathrow.
6.87 A number of approaches are available to terminal pricing and access, and in particular to
dealing with capacity constraints. The optimum arrangement, however, may depend on local
circumstances including the different business models and operational requirements of
different terminal users.
Barriers to entry
6.88 Denying operators access to a terminal, or discriminating in the allocation of capacity, may be
an abuse of a dominant position since it creates a barrier to entry.
6.89 We noted in paragraph 6.30 that our 2009 study had identified issues of abuse of dominance
in Spain and Poland, but that none of the stakeholders contacted in the current study had
identified this as a problem. Stakeholders did, however, identify potential or actual issues
related to terminals in other Member States, which we listed in Table 4.10 and summarise in
Table 6.6.
6.90 We note that some cases of anti-competitive behaviour can be addressed under general
competition law, as has been the case with the disputes at London Luton and Stansted airports
in the UK (see paragraph 4.69). However, market entry can be constrained by a lack of
capacity even in circumstances where no individual party is seeking to frustrate competition,
and the challenges of reallocating capacity or expanding terminal facilities are likely to be
considerable. Constraints of this kind are analogous to those at a number of major European
airports, which are designated as congested under EU legislation and subject to specific
capacity allocation rules, and on parts of the European rail network, which are similarly subject
to legislative provisions.
6.92 In our view, there is a case for considering the applicability of similar approaches to address
the issue of insufficient coach terminal capacity where it arises. In particular, the concepts of
designated or congested infrastructure appear relevant, as they support a case-by-case
assessment of capacity requirements, consistent with minimising the regulatory burden and
the development of a location-specific solution within a general framework. However,
established legislation in the aviation and rail sectors is based on well-defined terms that help
to ensure that regulatory processes are only triggered when specific criteria are met.
Accordingly, we summarise in Table 6.7 below a number of issues which would need to be
considered in the development of an equivalent approach in the coach sector. In each case we
highlight where the equivalent rail-sector issue is addressed in Directive 2012/34, the “Railway
Recast”.
Capacity allocation To define frameworks of how capacity should be allocated, consistent with practical
issues such as those that we described at London Heathrow and in our discussion of
barriers to entry.
Directive 2012/34 Section 3 deals with the allocation of infrastructure capacity.
Capacity constraints To define procedures for declaring terminals to be congested and for planning and
implementing capacity enhancements.
Directive 2012/34 Articles 47, 50 and 51 of Section 3 set out the concept of “congested
infrastructure”, “capacity analysis” and “capacity-enhancement plan” for railway
infrastructure.
Source: Steer Davies Gleave analysis, Directive 2012/34 establishing a single European railway area.
6.93 However, while the rail legislation identified in the table provides a useful precedent, any
analogous framework for addressing capacity constraints in the coach sector must take
account of the characteristics of coach operations. In our view, the greater flexibility of the
mode as compared with both rail and air, and the availability of business models of the kind
operated by Flygbussarna and Oxford Tube, mean that terminal capacity issues will generally
be less of a constraint on competition and the regulatory burden associated with enabling
access correspondingly less. It follows that the success of any future liberalisation measures,
whether introduced at the EU or national level, will be less dependent on relieving
infrastructure constraints.
Issue Comment
Usage of coach services by PRMs EDF members report that use of coach services is still limited, due to a lack of
accessibility of vehicles, terminals and also information, including the websites
of terminal operators and transport undertakings.
There is low awareness of the rights under Regulation 181/2011.
The Royal National Institute of Blind People (RNIB) in UK has campaigned for
more accessibility of bus services and conducted a survey of blind and partially
27
sighted persons about their experiences .
Barriers to coach travel for PRMs The main barrier is the accessibility of the services.
There are also attitudinal barriers and a lack of awareness of disability issues
by transport undertakings and the drivers. This could be improved by
consistent training on disability awareness and on practical issues, such as how
to assist a person in a wheelchair or how to communicate with a deaf person.
Attitudes towards coach travel See above.
and terminal facilities by persons
of reduced mobility
The implementation of It is problematic that, under Article 18 of the Regulation, carriers can be
Regulation 181/2011 (including granted an exemption from the obligation to train their staff, especially
any evidence of best practice) concerning the disability-related training (Article 16 (2).
Having the appropriate training when helping a PRM board a vehicle is
important for the safety of both PRM and member of staff, and lack of training
could mean endangering the health of either or both.
These exemptions should be revoked or at least not be prolonged.
7.6 Article 9 of Regulation 181/2011 provides for disabled persons and persons with reduced
mobility the right to transport, but this right remains theoretical while vehicles and terminals
are not accessible. Regulation 181/2011 did not introduce additional technical requirements
for buses, coaches and terminals, and consequently did not contribute significantly to raising
the accessibility level of vehicles and the transport infrastructure.
7.7 One stakeholder representing the interests of Europeans with disabilities suggested that use
of coach services by PRM might remain very limited unless there were investment in both
coaches and terminals. This implied that, for the situation to improve, at least some
investment must take place without either proven demand for facilities or scope to use them
without corresponding investment by other parties.
26
http://cms.horus.be/files/99909/MediaArchive/library/EDF_Position_Paper_Implementation_Reg181-
2011.pdf
27
http://www.rnib.org.uk/campaigning-current-campaigns/bus-campaign
7.8 Our discussion below focuses in turn on PRM provision on coaches and PRM provision at
terminals.
PRM provision on coaches
7.9 We asked the European Automobile Manufacturers’ Association (ACEA) and the International
Road Transport Union (IRU) whether they held any data on the proportion of coach fleets
equipped for PRM. Both informed us that they did not collect this data, but we identified
limited information, for a number of sources, on progress with the equipment of coach fleets
in some Member States, which we summarise in Table 7.2 below. A number of Member States
have or propose legislation to require that vehicles used for certain categories of services are
equipped to carry PRM.
Table 7.2: PRMs: progress with equipment of coach fleets
Source: www.checkmybus.com, national reports and statistics (see text), Steer Davies Gleave analysis.
7.10 In France, some coach operators mention accessible services for PRM, but it is unclear either
whether all coaches are accessible or what notice must be given by PRMs to operators.
Table 7.3: PRMs: provision by coach operators in France
Coach services
Operator Notice to be given by PRM Assistance available
amenities
Isilines/
Need to contact operator 36 hours
Eurolines Unclear Unclear
before departure
France
100% of coaches for
international
Ouibus services have a Need to contact operator 48 hours Website mentions assistance at
(was iDBUS) dedicated space for before departure at minimum departure and arrival points
one PRM and an
elevated platform
Starshipper Website states that services should be available “in a few months”
Some coaches have
Stagecoach dedicated space for Need to contact operator 48 hours
Unclear
France PRM and an before departure at minimum
elevated platform
FlixBus No information provided on website
28
http://ec.europa.eu/transport/themes/passengers/road/doc/designated_bus_terminals_en.pdf
7.19 We have not systematically visited designated terminals, but our desk research suggests that
the quality of PRM provision varies widely between Member States and between terminals
within a Member State or even within a city.
7.20 In Bulgaria, Plovdiv’s Rodopi bus terminal has been designated, but while it is adjacent to the
railway station it is connected to the south terminal (Автогара "Юг") and by a bridge over the
railway. We have not been able to confirm either the proportion of coaches which use the
designated terminal or the availability of assistance for connecting between the two terminals.
7.21 In Cyprus, the only designated terminal is in Nicosia, but we have not been able to confirm the
existence of any facilities other than a shade from heat and rain.
7.22 In France, the accessibility of coach services by persons with reduced mobility is highly
variable. Only 11 coach stations are able to provide assistance to PRMs: Paris-Bercy, Bagnolet,
Caen, Rouen, Strasbourg, Metz, Angers, Niort, Poitiers, Toulouse and Aix-en-Provence. In
addition, a law requiring public spaces to be accessible by 2015 has seen its deadline
extended, after only 40% of public spaces were found to comply. In the transport sector,
urban transport was given a time limit of three years, interurban transport a time limit of six
years and rail services a time limit of nine years.
Number of PRM carried
7.23 Figure 7.2 shows the percentage of the population in each Member State accounted for by
disabled persons (both requiring and not requiring assistance) and Figure 7.3 shows the same
data in terms of absolute numbers of people.
7.24 The former indicates that persons requiring assistance account for 5% or more of the
population in 10 Member States, including the UK and Italy, and close to 5% in a number of
other large economies such as France, Germany and Poland. Moreover, in France, Germany,
Italy, Spain and the UK the same category of disabled persons represents between three and
five million people.
7.25 While Member States identify the number of citizens or residents who are PRM, we did not
identify any requirements for operators to identify journeys made by PRM. The only data we
found on the number of journeys made by PRM in any Member States are:
In Denmark, the Danish Transport and Construction Agency reported 957,000 disabled
passenger journeys in 2015 (see Appendix B, B.127).
In Latvia, Road Transport Department data reported 1,503,868 disabled passenger
journeys in 2014 (see Appendix B, Table B.34).
7.26 In neither case have we identified what proportion of these journeys were by coach or on
regular, special regular or occasional services. However, both Denmark and Latvia have
designated only one terminal, so none of the journeys could have been by coach between two
terminals at which assistance was available.
7.27 We note that the PRM community across the EU represents a material potential market, and
that coach operators may be failing to capture significant numbers of passengers where they
fail to invest in facilities (whether vehicle or terminal-based) that support PRM travel.
7.28 Given this limited data, and Given the evidence of the difficulties faced by the PRM community
seeking to travel by coach (see Table 7.1), and in the light of the market potential suggested by
the figures above, we discuss below the obstacles to improving facilities for PRM.
Obstacles to improving facilities for PRM
7.29 A number of issues were cited as general obstacles to improving facilities for PRM including:
underlying terminal design, particular where there are multiple changes in level;
lack of space to provide facilities;
lack of funding to provide facilities; and
delays in implementing existing legislation (as in France, see Appendix A, A.191).
7.30 One issue mentioned by a stakeholder, as noted above, is that investment in terminals would
be of no value until services were provided on coaches adapted to carry PRM.
7.31 Equally, and as exemplified by Plovdiv, provision of assistance and facilities within a terminal
may be of little or no benefit if connections to other modes of transport are not covered by
the assistance or no practicable for a disabled person. In contrast to Plovdiv, we illustrate in
Figure 7.4 an example of a coach terminal with clearly designated step-free routes to other
transport facilities nearby.
7.32 One stakeholder commented that “There is a general lack of integration of coaches in the
door-to-door mobility chain, which impacts their capability to meet user needs. This is mostly
visible through the lack of bus and coach or multimodal terminal infrastructure in the EU and
the absence of harmonised rules ensuring equal and non-discriminatory access to existing
terminal infrastructure such as coach and railway stations. Access to existing terminals is often
reserved for local public services, to the detriment of long distance international and domestic
lines.”
7.33 The German BMVI suggested that “Sharing support staff between different modes of transport
could offer an improvement, particularly for PRMs making multimodal journeys.”29
7.34 A third issue, particularly relevant in Great Britain and to a lesser extent in Ireland, is the use of
right hand drive vehicles in these two Member States. Problems may arise where the same
vehicle operates in both left hand drive and right hand drive environments. Where
infrastructure (including not only on-street bus stops but also terminal bays and loading and
unloading facilities) is designed for vehicles with doors and wheelchair lift on one side, it may
be difficult or potentially dangerous to use a vehicle with them on the other side.
7.35 For regular services, this issue may be largely confined to left hand drive coaches, based in
continental Europe, which travel to London’s Victoria Coach Station, where buses load at right
angles to the kerb and wheelchair lifts on either side can be handled. For occasional services,
in contrast, which may collect passengers at locations such as schools and take them to a
range of points including tourist attractions with no off-street parking, loading and unloading
can be problematic. An interviewee showed us a popular tourist destination in central London
where coaches with doors and wheelchair lifts on the “wrong” side would need to unload
passengers and wheelchairs direct into a busy traffic lane.
7.36 A fourth issue, identified by a stakeholder in Great Britain, was the increasing number of
requests from the elderly to carry mobility scooters, which in some cases needed to be
dismantled so that they could be fitted on board. Article 3 of Regulation 181/2011 defines a
disabled person in a way (see paragraph 7.2) which appears likely to include those dependent
on mobility scooters, but no specific rules or code of practice are yet in place (see Appendix A,
A.358). In contrast, rail operators in a number of Member States make specific provision for
travel with mobility scooters, and provide detailed information on the maximum dimensions
and masses that can be accommodated.
Good practice
7.37 We identified examples of good practice in the provision of facilities and information at
terminals.
Provision of facilities for PRM
7.38 In Lithuania, the Klaipėda terminal, opened in 2009, has been designed to take into account
the needs of PRMs, with features including the following:
The terminal is built entirely at ground level.
All doors are marked with yellow slashes to help PRMs to find door handles.
There are automatic doors.
There are toilets specifically equipped for PRMs and are wheelchair accessible.
At the coach decks, large numbers have been painted on the floor to help those with
difficulty reading the display screens.
29
Die gemeinsame Nutzung von unterstützendem Servicepersonal, das für verschiedene Verkehrsträger
gemeinsam bereitgestellt wird, könnte zu einer verbesserten Situation insbesondere für multimodal
reisende mobil eingeschränkte Personen führen.
7.39 The Kaunas terminal is now being modernised, after which it will be fully suitable for PRM
travellers. As we note in Table 6.1, however, the Kaunas bus station is 400 metres from the
railway station.
Provision of information for PRM
In Sweden, there is consistent provision of information on step-free routes within terminals
for coach and rail travel. Figure 7.4 shows, as an example, the detailed provision of
information at the terminal in Luleå, including the recommended route (departing top right) to
the railway station, which is shown in the larger diagram from which we cropped the figure.
Figure 7.4: PRMs: good practice on terminal information and routes
Source: http://www.stationsinfo.se/station/, PRM routes shown in red, route top right leads to railway station.
Note: two local bus routes serve the stops on the left, but the main central bus interchange is 400 metres away.
withdrawal of coach services, or closure of coach terminals, if the parties concerned are
not willing or able to fund and make the necessary investment.
All Member States have now designated at least one terminal at which assistance is
provided, although a passenger will generally require assistance at both ends of a journey
and would, ideally, have access to assistance at all terminals and stopping points.
The provision of assistance in terminals may be of limited value if it is still not possible to
make connections with other modes within the area within which assistance is provided.
7.42 Accessibility has been limited in a number of Member States, particularly where provision is
technically difficult, unfunded, or seen as unlikely to be beneficial without simultaneous
investment in both coaches and terminals.
7.43 While we have not identified any data on coach travel by PRMs, evidence from EDF, and the
proportion of the population requiring assistance, suggest that PRMs represent a significant
potential market. This, in turn, indicates a need for further investigation of barriers to
investment in appropriate on-board and terminal facilities. Measures to encourage or even
mandate such investment would need to be developed in close collaboration with EDF and
other stakeholders, and strike a balance between improving accessibility of coach services to
PRMs on the one hand, and minimising the costs of market entry on the other.
8 Findings
Introduction
8.1 In this chapter, we discuss in turn our findings on:
the size of the domestic and international coach markets;
Regulation 1073/2009’s impact on administrative burden;
Regulation 1073/2009’s impact on travel markets;
Regulation 1073/2009’s categorisation of coach services;
Regulation 1073/2009’s reporting and monitoring arrangements;
access to terminals;
persons with reduced mobility;
further integration of the coach market; and
future monitoring and information provision.
The size of the domestic and international coach markets
The domestic coach markets
8.2 Table 8.1 reproduces Table 4.7 summarising our indicative estimates of European coach
market statistics, where possible focusing on data for the domestic market.
Table 8.1: Summary of indicative estimates of European coach market statistics
Source: Steer Davies Gleave analysis, 2009 and 2016, all estimates are indicative.
Note: employees in coach from Table 3.4 and Figure 3.8.
8.3 Our 2009 study estimated that the combined size of the domestic and much smaller
international markets in 2008 was 263 billion passenger-kilometres. We now estimate that the
size of the domestic market alone in 2014 was 285 billion passenger-kilometres. Both
estimates are subject to a wide margin of error (±25%).
8.4 Our estimates of employment in the domestic and international coach industry, shown in
Figure 3.8, suggest a slight decline in overall employment since 2008.
8.5 These estimates are consistent with the pattern of recession and slow recovery observed since
2009. They suggest that the coach market has been relatively stable during the recession,
although suppression of household income levels across much of Europe is likely to have
limited the ability of the industry to exploit the benefits of international and, in some Member
States, domestic liberalisation since 2009.
The international coach market
8.6 The international coach market is small compared with the domestic markets. We discussed in
Chapter 5 the limited value of the reporting required by Article 28 as a means of monitoring
the international coach market. Other than this, few Member States produce separate
statistics on international services, and the use of inconsistent definitions, coupled with the
Article 25 flexibility to limit or abolish control documents, limits the availability and reliability
of the information produced. As is the case in many liberalised markets, a common
unintended consequence of market liberalisation is a reduction in the quantity of data
available upon which to assess the success or otherwise of liberalisation itself.
8.7 Nevertheless, the evidence reviewed indicates that, subject to a number of assumptions,
between 2009 and 2014 the international coach market experienced growth of 50±10% in
passenger numbers and 20±20% in passenger-kilometres. Taken together, these estimates
suggest that the average international coach trip is getting shorter. Further, the data available
indicate consistent growth since 2010. Coupled with the data on control documentation
reported above, and against a backdrop of recession and slow recovery, this reinforces our
conclusion that international market liberalisation has supported the development of
competitive and responsive international coach services.
8.8 The data available do not allow an accurate estimate of the overall market size, but it may be
several tens of millions of passengers per year travelling, on average, several hundred
kilometres each.
Regulation 1073/2009’s impact on administrative burden
Introduction
8.9 Regulation 1073/2009 envisaged that:
“Administrative formalities should be reduced as far as possible without abandoning the
controls and penalties that guarantee the correct application and effective enforcement of this
Regulation.”
8.10 We identified neither any major criticism of the Regulation and its implementation nor any
evidence of a change in the administrative burden regarding the authorisation of international
coach services, except in the specific reference in the Czech Republic to increased flexibility for
cabotage.
8.11 The lack of major criticism of Regulation 1073/2009 suggests that it is not at the forefront of
operators’ or authorities’ considerations regarding barriers to market entry, and is not a
material deterrent to entry to international coach markets.
8.12 We attempted to estimate the net administrative and enforcement costs imposed or removed
by Regulation 1073/2009 relative to those in existence before it came into force. We assumed
that any change in the administrative and enforcement costs resulting from the model
documents provided in Regulation 361/2014 should not be attributed to Regulation
1073/2009.
Stakeholder perspectives
8.13 Our stakeholder questionnaire included three questions intended to gather information on the
net administrative burden of the Regulation:
What has changed since the entry into force of Regulation 1073/2009?
How many employees in your organisation are involved in the oversight and compliance
with coach service regulations, both national and international?
What are the estimated compliance and administrative costs for your members (as a
proportion of operating costs)? Do you consider these costs as proportionate?
8.14 On the changes since the Regulation, stakeholders rarely attributed to it any specific effects,
and in some cases asserted that there had been no material effect. We identified two specific
observations that the Regulation had had an impact:
A positive impact, highlighted by a stakeholder in the Czech Republic, was the automatic
authorisation of certain types of cabotage service under Article 15. We note (see Table
5.6) that one case of cabotage by regular services in the Czech Republic, and five in
neighbouring Germany, were authorised during 2014.
A suggested negative impact was that some Member States had been accused of
unnecessarily delaying authorisations by the maximum period permitted in Article 8.
However, we concluded that this cannot be attributed to the Regulation itself.
8.15 On the number of employees in oversight and compliance, none identified a change in either
the number of employees involved in, or the cost of, oversight and compliance.
8.16 Some stakeholders nevertheless commented that the administrative barriers to operating
international coach services remain high in some Member States. However, these comments
attribute the administrative burden to domestic practices outside the control and remit of the
competent authorities, rather than to Regulation 1073/200930. It may be the case that
respondents to the questionnaire are unable to distinguish the effects of Regulation
1073/2009 from domestic practices which hinder access to the international coach market.
8.17 On enforcement, stakeholders mentioned three specific points:
As mentioned in paragraph 8.15, a number of stakeholders suggested that some Member
States had been unnecessarily delaying authorisations by the maximum period permitted
in Article 8. However, there was no suggestion that the relevant Member States had
30
For example, from January 2015 operators of coaches transiting Germany must demonstrate that
they are paying the German minimum wage, with onerous requirements for transport companies. Local
rules also apply to the imposition of VAT based on the percentage of mileage operated in each country.
The requirement that VAT documents be submitted in each local language, combined with a
requirement for local legal and accountancy representation are seen to affect the smooth functioning of
the coach market, particularly for operators providing occasional services. Fines can range up to €7,000
if any discrepancies are found. However the European Commission has now opened an infringement
procedure (see http://europa.eu/rapid/press-release_IP-15-5003_en.htm)
previously issued authorisations more rapidly, or that the administrative burden has
increased.
A stakeholder in Italy (see Appendix A, A.210) expressed the concern that Article 8(4) of
the Regulation specifies grounds on which an authorisation may be refused, but makes no
provision for wider dialogue or consultation outside these grounds. However, the
stakeholder neither suggested how dialogue or consultation could be provided for in
legislation nor claimed that it could not be carried out by other means, such as through a
direct approach by the applicant to relevant stakeholders.
A national competent authority suggested that it would be useful to have a clearer
definition of the phrase “on a temporary basis” in relation to cabotage31.
8.18 We conclude that none of these points implies that an additional administrative burden has
been imposed by the Regulation.
Licences
8.19 In Chapter 5 we noted that at the end of 2014 there were nearly 36,000 Community licences
and nearly 300,000 certified true copies, each of which may be valid for up to ten years. This
suggests that the average annual workload may be around 3,600 licences and 30,000 copies
per year, or an average of around 125 licences and 1,000 true copies per year per Member
State. We note that small operators may only require either a licence or a copy infrequently,
but that their processing is otherwise a repetitive process which may be familiar to the staff
involved.
8.20 If the licence processes introduced by the Regulation had been materially more difficult than
the previous arrangements, we would assume that operators of wholly domestic services
would apply for local licences rather than Community licences, but there is no evidence that
this has been the case. However, none of the stakeholders mentioned that there had been any
material reduction in the time required to apply for or award a licence or certified copy. One
stakeholder suggested that it would be more sensible to have a public register of control
documents such as Community licences and authorisations, any of which could be
downloaded for checking.
Authorisations
8.21 In Chapter 5 we noted that at the end of 2014 there were 2,412 valid authorisations, which
may be valid for up to five years. If all these authorisations had been issued after Regulation
1073/2014 came into force on 4 December 2011, this would represent an average rate of 804
authorisations per year, or an average rate of 29 per year in each Member State.
8.22 Belgium accounted for the most authorisations of any Member States, issuing 436 by the same
date. If all these authorisations had been issued after Regulation 1073/2014 came into force
on 4 December 2011, this would represent an average rate of 145 authorisations per year. We
would expect that many of these would be renewals of existing authorisations and would in
many cases be subject to only limited examination unless market conditions had changed.
8.23 As we noted above, the only specific reference by stakeholders to the administrative burden
related to the automatic authorisation of cabotage services under Article 15. Article 15
31
Article 2 of Regulation 1073/2009 defines “cabotage operations” to include “national road passenger
services for hire and reward carried out on a temporary basis by a carrier in a host Member State”.
appears to allow that any existing regular international service is authorised to perform
cabotage. However, only one cabotage service has been identified in the Member State in
question.
Estimating the administrative burden of authorisations
8.24 The Commission gave us access to previous estimates of the expected savings of simplifying
authorisation procedure for regular international bus services32. These assumed that a
simplified procedure would deliver an authorisation three months earlier, and that for three
months, operating 20 days a month and 300 kilometres a day with an average load of 20
passengers paying €0.07 per passenger-kilometre, an operator would gain €25,000 in
additional revenue.
8.25 We note that this approach to estimating the effect of the Regulation:
may understate the benefits, because it seems unlikely that only a single bus would
operate on each authorised route;
may understate the benefits, because fares on many international routes exceed €0.07
per passenger-kilometre (see Figure 5.15); and
may overstate the benefits, because it takes no account of the costs of operating the
service.
8.26 We also note that the process may not actually delay service introduction, let alone by three
months, since operators familiar with it may simply submit applications further in advance. A
typical model is for an operator or group of operators to plan a network and seek
authorisations and then, once authorisations are in place, either to subcontract the operation
of the new services, or to acquire new vehicles, or to transfer resources from less profitable
routes.
8.27 While a number of stakeholders referred to delays with the application process, none of them
made any reference to either buses or staff being kept idle and wholly unproductive as a result
of delays in authorisation. None made any reference to a need for a new international regular
coach service emerging, but coaches and crew being held idle for months because of the need
to obtain an authorisation.
8.28 Nonetheless, we examined each step of the authorisation procedure for evidence that the
Regulation had resulted in any reduction in the administrative burden.
The authorisation procedure
8.29 Article 8 of the Regulation sets out an authorising procedure involving an applicant, an
authorising authority, and competent authorities of all Member States in whose territories
passengers are picked up or set down or whose territories are crossed without passengers
being picked up or set down. We note that authorisation may not be granted if, inter alia,
either:
A Member State decides on the basis of a detailed analysis that the service concerned
would seriously affect the viability of a comparable service covered by one or more public
service contracts conforming to Community law on the direct sections concerned.
32
Table 6.12 of “Impact assessment of legislative proposals on the admission to the occupation and
access to the market of road transport, Final Report”, ECORYS Nederland BV and NTUA, April 2007.
A Member State decides on the basis of a detailed analysis that the principal purpose of
the service is not to carry passengers between stops located in different Member States.
The workload of the applicant
8.30 The workload of the applicant directly related to seeking authorisation appears to be related
to completing an application. We note that the model application provided in Regulation
361/2014, which presumably is sufficient to meet the core requirements of all the Member
States, is two pages long. If a typical application required this volume of information, we
would not expect it to take more than an hour to complete.
8.31 However, “as appropriate”, the applicant must also attach timetable, maps, a certified true
copy of the Community licence and other information including maps and driving schedules.
Even so, one stakeholder informed us that applications are carried out as an occasional task by
staff with other main duties.
8.32 As we noted in paragraph 8.21, at the end of 2014 there were 2,412 valid authorisations. If all
these authorisations had been issued after Regulation 1073/2014 came into force on 4
December 2011, this would represent an average rate of 804 authorisations per year. If the
workload associated with each authorisation was one working day, then the total workload
across the EU28 would be equivalent to approximately three to four full time equivalent
employees.
8.33 If this workload for applicants before Regulation 1073/2009 came into force was twice as large
as now, the total EU28 administrative burden may have been reduced by up to three to four
full time equivalent employees. Assuming employment costs (salary, pension and other items)
of €50,000 per year this would mean an EU28 saving of between €150,000 and €200,000 per
year. In practice, however, no stakeholder mentioned that there had been any material
reduction in the time required to apply for, process, or comment on an application.
The workload of the authorising authority
8.34 The workload of the authorising authority directly related to progressing authorisation
appears to be limited to forwarding the application to competent authorities in other Member
States, awaiting responses, and either granting the authorisation, or stating the reasons for a
refusal, or referring the application to the Commission. We understand that this workload is
minor:
The Danish Transport and Construction Agency informed us that all domestic and
international authorisations were dealt with by two part-time staff.
One stakeholder forwarded us an operator’s comment that all applications for
international authorisations in Germany were dealt with by one person33. Germany had
199 valid authorisations and this person must therefore have processed at least 40 per
year.
8.35 This suggests that processing a small number of successful applications, plus a number of
unsuccessful ones on which we have no data, would rarely have required more than one full-
time employee per Member State, even before the harmonisation under Regulation
33
In context, the German BMVI identified at least 129 full-time equivalent staff administering coach
services at national and state level (see paragraph A.19).
1073/2009. In context, the German Bundesministerium für Verkehr und digitale Infrastruktur
indicated to us that an average cost per full time employee in Germany was around €85,000.
The workload of the competent authorities entitled to refuse the application
8.36 The greatest element of workload associated with authorisation may relate to the work by
competent authorities, which may be national, regional or local, in assessing the application
against the possible grounds for refusal in Article 8, and in particular the “detailed analysis”
(see paragraph 8.29) which is now required before an application can be refused.
8.37 In decentralised Member States, this workload might be carried out in parallel by a number of
regional and local competent authorities, whose approaches might range from welcoming any
new services to exploiting to the maximum the grounds for refusal or, in the event of finding
none, the two months permitted for a response.
8.38 Competent authorities which do not wish to authorise international services may still carry out
the detailed analyses listed in Article 8. We see no reason to assume that their workload will
have been reduced as a direct result of the Regulation, but note that it is largely self-imposed.
In Denmark, for example, the Danish Transport and Construction Agency has never refused a
request for international regular services (see Appendix A, A.85).
8.39 This kind of activity may continue to increase the administrative burden associated with access
to the international coach market and act as a barrier to entry. However, by specifying the
grounds upon which an authorisation may be refused, Regulation 1073/2009 limits the scope
for competent authorities to restrict the freedom to provide services and the free movement
of goods in a disproportionate manner. There may, therefore, be an indirect reduction in the
self-imposed workload of competent authorities as the body of case law in infringement cases
emerges.
Summary
8.40 Taken together, this analysis suggests that any direct reductions in administrative burden as a
result of the Regulation are likely to have been small.
8.41 However, if administrative procedures delay the redeployment of resources to more
commercially attractive routes there will be an associated opportunity cost. For example, if
serving an international route enabled the coach operator to generate returns of €0.10 per
passenger-kilometre (compared to, say, €0.07 per passenger-kilometre on the next best
domestic alternative) a delay of three months in the authorisation procedure would reduce
revenue by €10,800 per application. As described in paragraph 8.23, this assumes operating 20
days a month and 300 kilometres a day with an average load of 20 passengers.
Journey forms
8.42 Regulation 361/2014 provides a model journey form, which can be completed by the driver
before the beginning of each service.
8.43 We would expect the journey form to take less than an hour to complete, but note that the
time required for a driver to do so may need to be built into journey times and hence affect
overall costs and service quality. However, we note that in 2003 Denmark, Finland, Norway
and Sweden signed an agreement on abolition of the journey form when performing
occasional service in the Nordic countries. This suggests that:
The journey form has existed since before 2003, and Regulation 1073/2009 may have
introduced no net simplification.
Member States, or groups of Member States, may in any case have abolished journey
forms, eliminating them as an administrative burden.
8.44 We also note that the IRU suggested that journey forms for occasional coach services no
longer serve any purpose in the current market and their use should be discontinued. We
discuss elsewhere in this report the difficulties of monitoring the coach market if the
information provided on the journey form is no longer collected, collated or reported.
8.45 We conclude that the Regulation is unlikely to have had any material net effect on the
administrative burden of journey forms.
Enforcement
8.46 We would expect that, in the absence of direct complaints, Member States’ enforcement
activity would typically be based on inspecting foreign coaches and their documentation on a
sample basis. We do not consider it likely that the number of international coach services
operated or the type of documentation would be taken directly into account in setting staffing
and resourcing levels. However, by reducing the time needed to undertake enforcement
activities, inspectors will have more time to undertake other potentially more productive
activities. None of the stakeholders referred to any change in the levels of enforcement cost as
a result of Regulation 1073/2009.
8.47 Savings may be achieved, however, through the standardisation of documents across all 28
Member States. The disruption to coach operators and their passengers from inspection
should be less, with potential for both journey time and reliability improvements. However,
with no comprehensive data on the number of cross-border services, or on the origin and
destination of passengers using them, it is not possible to estimate the likely value of travel
time savings. These may have contributed to the benefits of Regulation 1073/2009.
Summary
8.48 Domestic liberalisation in some Member States can be expected to have reduced the overall
administrative burden for international regular services, for example by implicitly or explicitly
permitting cabotage, or abolishing documentation, whether the Regulation had come into
force or not. Domestic liberalisation may have reduced the scope for the Regulation to result
in any further net reduction of the administrative burden for these services.
8.49 We also noted (in paragraph 4.10) that the number and diversity of domestic regulatory
frameworks is expected to increase the administrative burden for operators seeking access to
more than one domestic market for regular services, since such access depends on the
different access rules of each Member State.
8.50 We conclude that most of the direct administrative burden associated with the regulatory
regime for international services is likely to be the largely self-imposed burden of national,
regional or local competent authorities choosing to seek refusal of an application on the
grounds set out in Article 8. Some competent authorities may already have agreed, alone or
with others, to waive their right to refuse an application, but others may incur as much effort
as they consider appropriate to carry out “detailed analysis” of applications which they are not
minded to grant.
8.51 On balance, we judge that the main reduction in administrative burden which is directly
attributable to Regulation 1073/2009 is that the standardised authorisation procedure set out
in Article 8 may have reduced the operators’ workload of completing applications to
authorising authorities by the equivalent of between three and twenty-one full time
equivalent members of staff. There may also have been benefits if the standardised
documentation results in lower costs and delays of inspection.
Regulation 1073/2009’s impact on travel markets
Introduction
8.52 We found a range of evidence that the market for regular international coach travel, as
measured by international routes, service frequencies and/or passenger numbers, has
expanded over the last five years. For example:
As summarised in Table 5.8, three out of the ten countries which provide such data
reported substantial increases in the numbers of international coach journeys.
As shown in Figure 5.13 and Figure 5.14, the limited time series evidence available
suggests that there has been a growth in international passenger numbers and
international passenger-kilometre.
8.53 However it has proved difficult to find evidence which directly links this increase in activity to
the introduction of Regulation 1073/2009, and little data is available from three of the largest
Member States (Germany, Spain and France), as we discuss briefly below.
Germany
8.54 On the limited and emerging evidence, domestic liberalisation appears to have had a
substantial impact on the number of international routes and service frequencies offered. For
example, following the liberalisation of the German coach market in 2013, start-up FlixBus
expanded rapidly within its domestic market, most notably through merging with competing
start-up MeinFernbus. In addition to operating international routes to Denmark, Sweden and
Belgium from Germany, the company has begun a programme of internationalisation through
entry into domestic markets. Since July 2015, FlixBus has entered the Italian, French and Dutch
markets and expanded its international route network to serve these countries. Of particular
note is its introduction of international services which do not have an origin, destination or
intermediate stop within Germany. Regulation 1073/2009 is likely to have enabled FlixBus’
rapid expansion into multiple domestic markets along international corridors, but it is not
possible to isolate the impact of domestic and international coach market liberalisation on
market entry.
8.55 Figure 8.1 summarises recent data from the German BMVI. The number of authorised services
grew from 86 in December 2012, the month before liberalisation, to 301, in September 2014,
although this may include multiple operators on the same route.
8.56 In the last quarter of 2014 and the first quarter of 2015 a market consolidation took place,
resulting in a reduction in the number of lines to 277 in March 2015. However, the March
2015 data do not include 26 requests for authorisation that were being reviewed by the
competent authorities.
Spain
8.57 A similar expansion and consolidation has been observed in the Spanish coach market.
Comparing operator and vehicle numbers in 2000 and on 1 January 2015 shows:
21% fewer operators, from 4,490 to 3,544;
25% more authorised vehicles, from 34,987 to 43,689; and, in consequence
58% more authorised vehicles per operator, from 7.8 to 12.334.
France
8.58 On the corridor between Paris and Milan (see Chapter 3, paragraph 5.21), once Regulation
1073/2009 came into force, Eurolines was for the first time permitted to offer coach services
which competed with SNCF’s domestic rail services in France. While the subsequent entry of
iDBUS (a subsidiary of SNCF) may have been an attempt to recapture a proportion of the rail
revenue lost to coach competition, the outcome was beneficial to consumers who could not
previously make domestic coach journeys and who could now choose between two competing
coach operators.
34
Observatorio del transporte de viajeros por carretera
Occasional services
8.59 Regulation 1073/2009 may, in practice, have a greater impact on operators that supply
occasional coach services, since the cost of authorisation and licensing is likely to be a greater
proportion of administrative costs than for larger operators providing regular services. For
example, in 2015 the Greek Ministry of Infrastructure, Transport & Networks stated that the
total number of tourist coaches was 7,300, compared with 5,400 recorded in 2009.
8.60 This view was supported by a number of stakeholders who suggested that legislative efforts
should focus on occasional services, given the large number of small operators in the sector.
However, our stakeholder engagement included few providers of occasional services, many of
which are operated by small companies.
Summary
8.61 We identified evidence of market entry and competition following the introduction of
Regulation 1073/2009, although this is largely anecdotal and insufficient to demonstrate a
causal relationship. Domestic liberalisation, in contrast, appears to have generated
considerable new activity within the European coach sector.
8.62 Finally, while domestic markets are typically larger than the market for international coach
travel, as recent experience in Germany suggests, once domestic markets reach a “critical
mass”, the barriers to operating international services are relatively small. In order to isolate
the impact of Regulation 1073/2009 it would be necessary to identify a large number of
additional international services in one or more Member States where there has been no
domestic liberalisation.
Regulation 1073/2009’s categorisation of coach services
8.63 We identified a number of potential issues with the current categorisation of coach services in
Regulation 1073/2009. While the definitions do not appear to create material difficulties at
present, we note that they might do so in a more liberalised environment, particularly if the
right to operate a service depended on a distinction which might be evaded or challenged. We
discuss in turn below the distinctions, set out in Regulation 1073/2009, between:
international and domestic services; and
special regular, regular and occasional services.
The distinction between international and domestic services
8.64 Regulation 1073/2009 Article 2 states that:
“‘international carriage’ means:
(a) a journey undertaken by a vehicle the point of departure and the point of arrival of which
are in two different Member States, with or without transit through one or more Member
States or third countries;
(b) a journey undertaken by a vehicle of which the point of departure and the point of arrival
are in the same Member State, while the picking up or setting down of passengers is in another
Member State or in a third country;
(c) a journey undertaken by a vehicle from a Member State to a third country or vice versa,
with or without transit through one or more Member States or third countries; or
(d) a journey undertaken by a vehicle between third countries, with transit through the
territory of one or more Member States;”
8.65 However, for a journey undertaken by a vehicle of which the point of departure and the point
of arrival are in the same Member State:
Article 2 (b) defines these journeys as international only if picking up or setting down
passengers in another Member State or a third country.
Article 8 requires that authorising authorities send copies of applications to Member
States whose territories are crossed without passengers being picked up or set down.
8.66 This means that a journey not defined to be international must still be notified to Member
States “whose territories are crossed without passengers being picked up or set down”. We
note that there may be good reasons for Member States to be informed of “domestic”
services which cross their territory, even briefly, for reasons including security and safety.
Nonetheless, it is not clear why these services should be treated as domestic in these
circumstances.
8.67 One possible clarification would be to modify Article 2(b) to define international services to
include all cross-border services:
“(b) a journey undertaken by a vehicle of which the point of departure and the point of arrival
are in the same Member State, passing through another Member State or a third country;”
8.68 We do not yet foresee that the classification of such trips is likely to be critical, and note that
there may be precedents from other sectors for the classification of “domestic” journeys
passing via another Member State.
The distinction between regular and special regular services
8.69 We note that a typical distinguishing feature of special regular services is that they are
provided for a clearly identifiable group of passengers, and that they shall include:
school children or students, typically identifiable by being enrolled at a particular
education establishment; or
staff or workers, typically identifiable by having passes to work at a particular location.
8.70 However, the requirements of the Regulation are that:
“Special regular services shall include:
(a) the carriage of workers between home and work;
(b) the carriage of school pupils and students to and from the educational institution.
The fact that a special service may be varied according to the needs of users shall not affect its
classification as a regular service.
Special regular services shall not be subject to authorisation in accordance with Chapter III
where they are covered by a contract concluded between the organiser and the carrier.”
8.71 This does not limit them to the carriage of workers, school pupils and students, and exempts
them from authorisation when there is a contract between the carrier and the “organiser”. We
note that there are precedent of “spurious” groups being created to take advantage of
different legislation applied to them. Examples we identified include:
Shuttle services
8.79 In addition to these categories, Regulation 684/92 also defined a distinct category of shuttle
services which is neither defined nor referred to in Regulation 1073/2009. We did not identify
whether shuttle services are defined or regulated separately in any Member States or, if so,
whether there would be any practical difficulties in removing such a distinction. However, we
noted a number of types of shuttle service in Table 2.2, and note that it might be that there
are grounds for reintroducing a distinct category of shuttles, whether as defined in Regulation
684/92 or not.
Regulation 1073/2009’s reporting and monitoring arrangements
8.80 Our 2009 study of the coach sector, and more recent studies of other sectors, have revealed a
lack of sufficient consistent data to enable the Commission, Member States and competent
authorities to monitor and plan and to predict the impacts of proposed change. Given these
problems in the past, the collection of detailed statistical transport data was excluded from
the scope of the study.
8.81 The lack of sufficient consistent data may be exacerbated where:
information provision specified in European legislation, such as through Article 28 of
Regulation 1073/2009, is of limited value in monitoring the market, as we discussed in
Chapter 5;
operators have disincentives to provide information or incur the cost of collecting it;
competent authorities have disincentives to impose data requirements on operators;
and/or
Member States have disincentives to collate and publicise industry data.
8.82 Generating, collecting, collating and analysing industry data on a consistent basis is potentially
difficult and costly, but the aviation industry shows how a consistent approach can ensure that
the burden of data provision falls equally on all operators and can facilitate monitoring and
planning. It may be appropriate for further liberalisation to be accompanied by measures to
establish a harmonised, non-discriminatory and proportionate system of collection, collation
and reporting of industry data.
8.83 At first sight, it would appear desirable for the Commission, the Member States and the public
to have access to robust market information, ideally disaggregated sufficiently to distinguish
activity in the many international and domestic bus and coach markets listed in Table 2.2.
8.84 However, as we identify in Table 8.2, there may be a number of practical barriers to
monitoring the market in detail.
8.85 A wider issue is that liberalisation tends to involve the simplification and removal of
paperwork and control documents which form the basis of statistical analysis and reporting.
Among the case studies and fiches, for example, we contrast the following:
In regimes with concessions or service authorisations, such as Spain, extensive data on
regional and national services is available as a consistent time series.
In the long-liberalised regimes in Sweden and the UK, and the newly-liberalising Germany,
little reliable market data is available as a consistent time series.
8.86 This suggests a need for structured reporting arrangements, possibly similar to the Rail Market
Monitoring Scheme, in order to obtain robust data that can be used in assessing the impact of
regulation and the evolution of the coach market more generally. However, a balance would
need to be struck between obtaining reliable data, on the one hand, and avoiding the
imposition of onerous reporting requirements on bus operators (many of whom are relatively
small businesses), on the other.
Access to terminals
8.87 As we set out in Table 6.6, repeated as Table 8.3, there have been a number of reports of
discriminatory access to terminals, or abuse of dominance, which can act as a barrier to entry.
Table 8.3: Terminals: barriers to entry
8.89 It would be preferable for access to be non-discriminatory and for abuse of dominance to be
prevented, as is now required in relation to access to airports and rail infrastructure. Measures
to prevent discriminatory practices and abuse of dominance should be further considered.
Persons with reduced mobility
8.90 Disabled passengers’ rights to assistance under Regulation 181/2011 also remain theoretical
as long as vehicles and the transport infrastructure are not accessible:
A number of Member States have set deadlines by which all coaches will need to be
accessible. There is, however, a risk that a requirement for higher standards results in
withdrawal of coach services, or closure of coach terminals, if the parties concerned are
not willing or able to fund and make the necessary investment.
All Member States have now designated at least one terminal at which assistance is
provided, although a passenger might require assistance at both ends of a journey and
would, ideally, have access to assistance at all terminals and stopping points.
The provision of assistance in terminals may be of limited value if it is still not possible to
make connections with other modes within the area within which assistance is provided.
8.91 It is not clear whether operators or terminal owners will find it commercially attractive to
invest in facilities for PRM, or whether it will be necessary for competent authorities to
provide investment, either by contributing to the cost of terminal facilities or by increasing
PSO payments to cover the cost of PRM-equipped coaches. However, evidence provided by
EDF, and the proportion of the population requiring assistance, suggest that PRMs represent a
significant potential market. We consider that further investigation of the barriers to
investment in both on-board and terminal facilities is required. This would inform
consideration of the balance between encouraging greater coach travel by PRMs and ensuring
that any associated costs of compliance for operators are proportionate.
The potential impacts of further liberalisation
8.92 The anticipated benefits of liberalisation of the coach market are clearly described in the
intervention logic for Regulation 1073/2009. Through a range of measures designed to open
competition for international and domestic commercial (non-PSO) bus and coach services and
providing coherent framework conditions for operating bus and coach services in the EU,
liberalisation is expected to35:
Provide better quality and more reliable bus and coach services;
Lower the price of coach services;
Deliver a better modal mix of passenger transport, with a positive impact on overall
passenger transport sustainability; and
Reduce interurban congestion, air and noise pollution and greenhouse gas emissions as a
consequence of mode shift from car.
8.93 Our examination of liberalisation, and particularly commentaries and reports on the recent
liberalisation of the German and French domestic markets, reveals evidence to suggest that
the range of objectives for coach market liberalisation are, to a greater or lesser degree, being
delivered.
8.94 For example, following the liberalisation of the German coach market in 2013, FlixBus
expanded rapidly within its domestic market, most notably through merging with competing
start-up MeinFernbus. In addition to operating international routes to Denmark, Sweden and
Belgium from Germany, the company has begun a programme of internationalisation through
entry into new domestic markets. Since July 2015, FlixBus has entered the Italian, French and
Dutch markets and expanded its international route network to serve these countries.
8.95 Elsewhere, as observed in our international case-study of the Baltic corridor and western
Europe, there is evidence that market liberalisation has led to both price competition and
product differentiation. For example, the low-cost brand Simple Express was introduced by
Lux Express Group in April 2010 on the basis of evidence which demonstrated that the fastest
growing markets for coach travel were small and medium enterprises looking for ways to
reduce the cost of business trips, and young people seeking to travel for as little cost as
possible.
8.96 Shortly after the introduction of Simple Express services, in June 2011 the company began a
price war against its competitors, lowering the fare on the Vilnius-Warsaw route to less than
35
See Evaluation of Regulation (EC) No 1073/2009 (http://ec.europa.eu/smart-
regulation/roadmaps/docs/2016_move_011_evaluation_passenger_coach_bus_transport_en.pdf)
€3. At the end of 2015 the company introduced a new dynamic pricing model inspired by the
practice of low cost airlines and other low-cost coach operators such as Megabus, offering
ticket prices starting from €1.
8.97 Emerging evidence from France and Germany also suggests that the liberalisation of domestic
coach markets has led to broad-based growth in patronage both from new users and through
mode shift. In the six months since enactment of the Macron law, it has been reported that
over 1.5 million coach journeys have been made in France36. In Germany, the intercity coach
market grew by 25% in 2015 compared to 2014, with a significant proportion of demand
transferring from less sustainable modes including the private car37.
8.98 Notwithstanding the successes described above, our examination of liberalisation also reveals
a number of potential issues which need to be considered in advance of further liberalisation.
For example, as in Germany, sudden liberalisation may exacerbate a shortage of terminal
capacity. In a recently-liberalised market it may be difficult to predict whether, where or what
size of terminals are required. In those cases in which terminal capacity is likely to be a
constraint, mechanisms to ensure fair access rights to terminals may need to be established.
8.99 Second, liberalised markets may consolidate rapidly. This phenomenon has been repeatedly
observed in deregulated transport markets, and within two years of liberalisation it appears
that a single operator may emerge with over 50% of the liberalised German market. This does
not mean that the outcome will be anti-competitive as rail, coach and aviation may compete
actively with each other for certain market segments, but does suggest that liberalisation may
not, in itself, prevent the emergence of local monopolies. Adequate protections (which may
extend beyond the remit of national competition authorities) may need to be established to
avoid abuse of market power by either coach and terminal operators.
8.100 Third, deregulated regular coach services appear likely to target markets served by rail, in
particular where coach can operate non-stop on a motorway parallel to a rail service which is
limited in speed by infrastructure or intermediate stops. From a social welfare perspective this
is perceived as a benefit since, following the liberalisation of coach services, passengers will
choose the combination of fare, journey time and quality which maximises their personal
utility or wellbeing. However, from an affordability and equity perspective, unrestricted coach
competition to PSO rail (or coach) services may result in either greater subsidy needed to
support PSO services or contraction of services operated commercially by incumbent
operators or market entrants.
8.101 As discussed in the following sections, it would be desirable for any further liberalisation to be
designed to meet clear objectives, couched in terms of benefits to passengers and operators.
However, decisions would be required on:
the objectives to be pursued, and the relative weightings to be given to them;
the scope of services to be liberalised;
mechanisms to protect PSO services, which might need to be simplified and/or
harmonised between coach and other modes; and
36
See http://www.lesechos.fr/industrie-services/tourisme-transport/021732923777-six-mois-apres-
la-loi-macron-15-million-de-voyages-par-autocar-1203693.php
37
See
https://www.destatis.de/DE/PresseService/Presse/Pressemitteilungen/2015/02/PD15_043_461.html
whether fares and ticketing should be liberalised, regulated or integrated, either within
the coach sector or between coach and other modes.
Issues for further market integration
8.102 On the basis of our findings during this study, and drawing upon the discussion above, we
identified areas where further improvements or changes may be necessary in order to achieve
further integration in the market for coach travel. The issues we considered are summarised in
Table 8.4.
Table 8.4: Issues for further market integration
Issue Considerations
Objectives It may be useful to articulate possible or actual objectives.
The scope of services to Issues to consider include:
be liberalised What domestic services should be liberalised.
The boundaries or categories of services liberalised (see Table 2.2) and whether
these should reflect the categories of international services defined in Regulation
1073/2009.
Mechanisms to protect Issues to consider include:
PSOs The need to protect PSO services.
The range of PSO services to be protected.
The potential need for clear and rapid procedures.
Whether the protection should be based on rules or specific types of analysis.
The potential for inconsistencies in the way different modes are treated.
Access to infrastructure Issues to consider include:
The actual and potential scale of infrastructure constraints.
The existence of alternatives.
The structure of the market.
The scope for use of general competition legislation.
The scope for formal regulation of access and charging.
Fares Issues to consider include:
Whether fares should be liberalised or regulated.
Whether integrated ticketing between coach operators should be forbidden,
permitted or mandated.
Whether integrated ticketing between coach and other modes should be forbidden,
permitted or mandated.
Monitoring and Issues to consider include:
information provision The need for data on international services to be reported by Member State pair.
The potential need for the Commission, the Member States, the industry and its
customers to monitor developments.
The need for consistent and cost-effective collection of data.
The tension between simplifying or abolishing documentation and collecting
information.
The benefits of active monitoring of the market.
Source: Steer Davies Gleave analysis, note that Member States may liberalise further.
8.106 We also note that “integration” and “liberalisation”, while both potentially positive objectives,
may prove to be incompatible in a number of ways, such as:
Are modes required or permitted to collaborate (“integrated”) or compete (“liberalised”)?
Are fares required or permitted to be inter-available (“integrated”) or not (“liberalised”)?
8.107 Previous studies of market liberalisation, including our work on the Fourth Railway Package,
have identified potential tensions between these two objectives, in particular that it is difficult
to legislate to require both integrated ticketing and price competition.
The scope of services to be liberalised
8.108 We noted above how Regulation 1073/2009 subdivides coach services between:
international and domestic services; and
special regular, regular and occasional services.
8.109 This implies that, potentially at least, there are a wide range of approaches to liberalisation
(see Appendix C, Table C.3).
Liberalisation of services defined to be international
8.110 There may be scope for further liberalisation of services defined to be international, as
permitted under Article 25 (1) of the Regulation. We note that in 2003 Denmark, Finland,
Norway and Sweden signed an agreement on abolition of the journey form when performing
occasional service in the Nordic countries. This suggests that one possible avenue for further
8.119 Potentially the simplest test would be to permit any coach service, provided that each
passenger was carried at least a minimum (great circle or “straight line”) distance, such as 50
kilometres, making it clear to potential entrants what services would and would not be
permitted. This approach was formerly used in the United Kingdom and forms part of the
current tests in France, Germany and Sweden.
8.120 Such a simple test might unintentionally prohibit services which would in practice be no threat
to other PSOs, but any scope for appeal or negotiation raises further issues, such as identifying
the PSO service(s), and hence competent authority(ies) affected, establishing what further
tests should be applied, and the burden of proof, which might lie with the entrant, the
incumbent(s) or be subject to decision or adjudication by an independent body. Any of these
processes is likely to add time, cost and the potential for legal challenge, which may be
disproportionate for small services of for small changes to existing services.
8.121 Additionally:
Regulation 1370/2007 permits exclusive rights to protect any PSO provided by any mode.
Regulation 1073/2009 requires that international coach services be authorised except on
the basis of detailed analysis of their effect on one or more PSCs.
Directive 2012/34 requires that international rail services may be limited to protect the
economic equilibrium of a PSC.
Member States or competent authorities may selectively waive the powers to grant
exclusive rights or restrict services, with the effect that a service may be permitted by one
mode and forbidden by another.
8.122 The resulting growing complexity, and the potential liberalisation of the large and often
dynamic domestic coach markets, raises the issue of whether further liberalisation should be
combined with further harmonisation between modes, and in particular between coach and
rail, so that the restrictions are independent on the modes of existing and new services38.
Fares
8.123 Regulation 1073/2009 specifically envisages that a carrier offers lower prices than others, but
in some liberalised markets competition between operators is partly or wholly based on
connectivity (which destinations are served) or quality, rather than on price, which is expected
to be standardised across the network with tickets inter-available between carriers.
8.124 Fourth Railway Package proposals to modify Regulation 1370/200739, rather than specifying
that rail operators should compete on price, explicitly envisaged “voluntary national
integrated ticketing systems” and does not state that these should be limited to rail. The
balance of advantage of integration and competition within the rail and coach modes may be
different, but any policy requirement for fares integration between modes might necessarily
38
One stakeholder pointed out that, in Scotland in 2013/14, 425 million bus journeys each received an
average support of £0.126, and 86 million rail journeys each received an average support of £9.63, over
75 times more. Even if adjusted for average journey length (which we do not have) to calculate an
average support per passenger-kilometre, this suggests that rail receives much greater subsidy per
passenger-kilometre than bus.
39
“Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending
Regulation (EC) No 1370/2007 concerning the opening of the market for domestic passenger transport
services by rail”, 30 January 2013.
lead to elements of fares harmonisation within each mode, including coach, the extent and
nature of which would need to be specified.
8.125 A further issue relevant to coach markets is the extent to which coordination or integration of
fares should be permitted or required, which we discuss briefly below.
8.126 Regulation 1073/2007 Article 4 states that:
“The fact that a carrier offers lower prices than those offered by other road carriers or the fact
that the link in question is already operated by other road carriers shall not in itself constitute
justification for rejecting the application.”
8.127 This explicitly envisages that a carrier offers lower prices, and implicitly assumes that fares are
not inter-available between operators, as is often the case in other modes and is a specific
feature of one model of rail liberalisation.
8.128 In most Member States, a single national and publicly-owned rail operator has been
responsible for all domestic services and has provided a consistent approach to fares including
common types and conditions of ticketing and the sale of through tickets between any two
points in the network. Under progressive rail liberalisation since 1988 (beginning in Sweden)
there has been considerable divergence from this model, including variations such as:
Each operator is free to devise and set their own fares, and no through fares exist.
Through fares must be offered and “inter-available” (accepted by all operators), but
operators are allowed to offer lower fares on their own services.
Long-distance fares are not regulated, but operators of long-distance services must accept
locally-priced tickets for short distance journeys.
8.129 Airlines in the global aviation market have found that it is commercially valuable to have
“interline” agreements to enable them to offer through fares and through baggage services.
Great Britain’s railway requires that fares are available between any two stations, and are
accepted by all operators, and imposes processes for apportioning the revenue to operators.
8.130 Some domestic coach markets are not highly regulated but in others, particularly where
travellers are accustomed to an incumbent national operator providing a consistent level and
quality of service, there may be an expectation that through and inter-available fares will be
available.
8.131 We conclude that action to liberalise coach services may, as with the Fourth Railway Package,
need to consider:
whether fares offered by different operators should be liberalised, regulated or
integrated;
whether integrated ticketing between coach operators should be forbidden, permitted or
mandated; and
whether integrated ticketing between coach and other modes should be forbidden,
permitted or mandated.
Future monitoring and information provision
8.132 Our 2009 study identified that one of the principal difficulties of studying the long-distance
coach market was the lack of reliable, consistent and comprehensive information on coach
operations. This included not only detailed information on customer satisfaction (we noted
that private companies have no obligation or indeed incentive to publish service quality
40
“Study of passenger transport by coach”, 4.70.
Appendices
Germany
Introduction
A.2 The market for long-distance regular coach services in Germany was strictly regulated until
January 2013 when the market was fully liberalised. Up to this date, the authorisation of long-
distance regular coach services was restricted to those services that did not hinder the
“transport interests of the public”. Liberalisation brought an open market in which bus
undertakings wishing to enter the market are required to fulfil exclusively objective criteria.
This means that the subjective criteria which previously protected long-distance rail services
from coach competition ceased to apply.
History of coach services in Germany
A.3 The strict regulation of long-distance regular coach services in Germany dates back to the late
nineteenth century when railway networks were expanded and private railway undertakings
were nationalised. The state aimed to protect its investments and the profitability of its
services from ever-increasing competition from road transport.
A.4 Following multiple directives on commercial road transport, the first Passenger Transportation
Act (Personenbeförderungsgesetz (PBefG)) came into force in 1934. In accordance with this
act, regular bus services required authorisation which was only granted if services were not
adverse to the transport interest of the public and also brought macroeconomic benefit. The
motivation behind these restrictions was a desire for non-destructive competition and
protection of income of the public railway undertakings.
A.5 In order to permit entrance the market for long-distance regular coach services, the PBefG
required bus and coach operators to fulfil both objective criteria, such as safety and capability
requirements, and discretionary criteria applied by the competent authority. For decades,
these discretionary criteria guaranteed the German incumbent rail operator, Deutsche Bahn
(DB AG), protection from intermodal competition from coach services. This protection was
based on the rationale that the “transport interests of the public” must be upheld. In
particular, competition from coach services was not permitted where:
The service in question could be provided with the existing transport supply;
The service in question would not significantly improve services already offered by
existing operators or railways; or
Existing services were incomplete, but existing operators were willing to improve
services within a time limit set by the competent authority.
A.6 These restrictions were retained in the amendment of the PBefG in 1961. However, the
rationale for restrictions shifted from protection of rail services from intermodal competition
to a responsibility of the state to provide rail services as part of its public service obligation.
A.7 Regular coach services between West Berlin and Western Germany constituted an exception
from the strict regulation. These were viewed as providing transport independent of the rail
services of the former German Democratic Republic (GDR). Following German reunification,
these services were retained on the basis of protection of acquired rights of the bus operators.
A.8 Despite the 1994 railway reform removing DB AG’s obligations to provide long-distance
services, restrictions for long-distance regular coach services were retained as the PBefG had
not been substantially amended since 1961. For example, in 2005, DB AG brought an action
against Deutsche Touring for operating regular services between Dortmund and Frankfurt.
point of the service, even if the requested service passes through the territory of multiple
competent authorities. However, all municipalities, road authorities and competent
authorities that are affected by the proposed service are involved in the authorisation process.
A.18 The time required by the competent authority to grant route authorisations is usually three
months. In exceptional cases, such as if the authority requests the submission of further
documentation, this time might be extended by a further three months. Once the
authorisation has been granted, the operator is bound to run the service and adhere to the
timetable. Changes to the timetable need to be communicated to the competent authority
and the withdrawal of a service needs to be notified at least three months in advance.
A.19 The Ministry of Transport and Digital Infrastructure (BMVI) informed us that it employed 10
full-time equivalents (FTEs) in the administration of domestic and international coach services,
and that 13 of the Länder reported a further 119 FTEs.
The market for coach travel
General trends
A.20 The domestic long-distance regular coach network has developed continuously since the
liberalisation of the market in 2013. Figure A.1 summarises recent data from the BMVI. The
number of authorised services grew from 86 in December 2012, the month before
liberalisation, to 301, in September 2014, although this may include multiple operators on the
same route.
Figure A.1: Germany: authorised long-distance regular coach services
350
300
Number of route authorisations
250
200
0
February
September
September
June
June
December
December
March
Decemner
March
A.21 In the last quarter of 2014 and the first quarter of 2015 a market consolidation took place,
resulting in a reduction in the number of routes to 277 in March 2015. However, the March
2015 numbers do not include 26 requests for authorisation that were being reviewed by the
competent authorities.
A.22 The Federal Statistical Office (Destatis) estimates the 2014 market for long-distance regular
coach services in 2014 at between 17 and 19 million passengers, although this is an estimate
as data is available from the incumbent coach operators but not from the new entrants41.
41
Destatis (2015) 2014: Fahrgastaufkommen in Bussen und Bahnen weiter auf Wachstumskurs, press
release 121/15 of 7 April 2015
Coach network
A.23 Figure A.2 shows the number of departures for cities with more than 100 weekly departures.
Figure A.2: Germany: cities with over 100 coach service departures per week
Source: Bundesamt für Güterverkehr (BAG) (2015), see text for further details.
A.24 Many routes, including the first new ones, follow the long-distance rail network, known as
“racetracks” (Rennstrecken). A study by the Federal Office for Goods Transport (Bundesamt
für Güterverkehr (BAG))42 suggests that densest routes are those shown in Table A.2.
Table A.2: Germany: densest coach routes
former border
Service across
Mannheim,
Ruhr, Köln
Hannover,
Karlsruhe,
Würzburg
Nürnberg
München
Frankfurt
Hamburg
Stuttgart
Dresden
Bremen
Leipzig
Berlin
42
BAG (2015) Marktbeobachtung Güterverkehr, Marktanalyse des Fernbuslinienverkehrs 2014
A.28 A fuller disaggregation of the source of coach passengers is provided in Figure A.3.
Figure A.3: Germany: source of coach passengers by previous mode (2014)
3% 10%
4%
1%
A.29 However, BAG suggests, on the basis of consultations with different market players, that the
30% share of coach passengers taken from rail is an overestimate because the railways’
previous monopoly meant that most current coach passengers had used rail services in the
past. BAG estimates from its own surveys that only 10-15% of current coach passengers have
changed from rail.
Coach terminals
A.30 The BMVI informed us that 43 terminals had been identified nationally, but these could not be
ranked in importance because exact passenger numbers were not available. Terminal are
often owned by local or regional authorities or airports, but may be leased to an operating
company. Dedicated long-distance regular coach service terminals only exist in Hamburg,
Berlin, Mannheim, Munich and Hanover.
A.31 The BMVI informed us that there had been no issues of discriminatory practice in access to
terminals .However, since market liberalisation in 2013 the number of routes and the number
of passengers has increased strongly, mainly between large urban agglomerations, and many
cities now face problems due to the lack of adequate terminal infrastructure. Private long-
distance regular coach services often stop at terminals designed for public local transport,
which still takes priority, and many are now at capacity with the large number of additional
services.
A.32 As a consequence there is now a debate on whether terminals for long-distance regular coach
services should be financed by public or private funds:
The German Association of Cities and Towns argues against funding by the municipalities
and for the participation of the Federal Government, which is the body responsible for
long-distance transport infrastructure planning and funding.
The Federal Government, represented by the Ministry of Transport, claims that coach
operators themselves are responsible for the funding of terminal infrastructure.
A.33 Despite this debate, the municipalities of Hamburg, Hanover and Munich took the decision to
fund dedicated terminals for long-distance regular coach services in their respective cities.
Persons with reduced mobility
A.34 The amendment of the PBefG defines specific technical specifications for the accessibility of
vehicles used for long-distance regular coach services. Two dedicated spaces for wheelchairs,
and an on-board lift system to assist boarding of persons with reduced mobility (PRM), will be
required:
from January 2016, on all new buses and coaches; and
from January 2020, on all buses and coaches in operation.
Summary of key issues
Interpretation of minimum distance between stops of 50 kilometres
A.35 The amendment of the PBefG states that authorisations for regular coach services may only be
granted if the distance between two stops is larger than 50 kilometres and there is no existing
regional rail service with a journey time of up to one hour connecting these stops. However it
does not give more detailed statements of how these 50 kilometres are defined, such as which
exact locations are used for measuring the distance and how this distance is measured.
A.36 The Federal Government, in conjunction with the Expert Committee of the Federal States, has
since provided instructions on the practical application of the amended PBefG. It was further
agreed that competent authorities should consider these instructions during the process of
granting authorisations.
A.37 These instructions state that the definition of the location of a stop may be interpreted either
narrowly or widely:
The narrow interpretation takes account of the exact location of a coach stop and allows
coach services between two municipalities if the railway station and the coach stop are far
apart.
The wider interpretation takes into consideration the journey length of the regional rail
service between the two municipalities in which the stops are located, irrespective of the
exact location of the coach stop. Authorisation for the coach service may not be granted if
the journey time of the regional rail service is below one hour. Therefore, the decisive
factor is the municipality, and not the exact location of the stop.
A.38 The instructions on the practical application of the amended PBefG generally recommend the
application of the wider interpretation, as this follows the purpose of the regulation more
closely and is in the interest of passengers. However, it also states that each case needs to be
assessed individually43.
43
KCW (2014) Neue Fernbushalte und Genehmigungspraxis, Chancen für die Kommunen
Access to terminals
A.39 While we note above the general shortage of terminal capacity, we were not able to speak to
either a terminal operator or representatives of the Association of Paneuropean Coach
Terminals. It is not yet clear how either allocation of capacity, in the short term, or expansion
of capacity, in the longer term, will be dealt with, or whether there have been complaints of
discriminatory practices.
Table A.3: Germany: translation of key terms
German English
Bundesverwaltungsgericht Federal Administrative Court
Bundesländerfachausschuss, BLFA Expert committee of the Federal States
Deutscher Staedtetag German Association of Cities and Towns
Instructions on the practical application of the
Hinweise zur Anwendung des novellierten PBefG
amended Passenger Transportation Act
Personenbeförderungsgesetz Passenger Transportation Act
Straßenverkehrsordnung StVO Road Traffic Regulations
Information sources
BAG (2015) Marktbeobachtung Güterverkehr, Marktanalyse des Fernbuslinienverkehrs 2014.
BMVI (2015) http://www.bmvi.de/SharedDocs/DE/Artikel/LA/fernbusse-
liberalisierung.html.
Destatis (2015) 2014: Fahrgastaufkommen in Bussen und Bahnen weiter auf Wachstumskurs,
press release 121/15 of 7 April 2015.
FIS (2015) http://www.forschungsinformationssystem.de/.
IGES (2014) Bahnkunden und Autofahrer lassen Fernbusmarkt wachsen, press release of 17
April 2014.
KCW (2014) Neue Fernbushalte und Genehmigungspraxis, Chancen für die Kommunen.
Greece
Introduction
A.40 Long-distance coach services in Greece remain highly regulated. The State grants exclusive
rights to two main categories of operator:
KTEL companies (Joint Receipts Fund of Buses) operate strictly regulated regular domestic
services. KTEL companies can also perform certain forms of occasional transport, as
described below.
“Tourist coaches” operate regular or occasional international services, and occasional
domestic services under looser regulatory conditions.
A.41 The institutional and regulatory framework for both categories of operator is specified by
national authorities at ministry level, while implementation is relegated to local authorities.
The Passenger Transport Directorate (General Administration for Transport) of the
Ministry of Infrastructure, Transport & Networks is responsible for the overall institutional
framework and preparation of legislation on the strictly regulated domestic services and
KTEL services overall. The Directorates for Transport & Communications of the Regional
Units (supervised by the Ministry of the Interior) are competent for the implementation of
the institutional framework and supervision of local KTEL.
The Ministry of Tourism is the authority primarily responsible for the institutional and
regulatory framework for tourist coaches, with local administrations (whether
Directorates for Transport & Communications of the Regional Units or local branches of
the Ministry of Tourism) again competent for the implementation of the framework. The
Passenger Transport Directorate of the Ministry of Infrastructure, Transport & Networks
retains a co-competence for tourist coaches alongside the Ministry of Tourism.
A.42 The State’s aim is the availability of secure, sufficient, high quality, efficient and affordable
passenger transport, covering domestic and international, regular and occasional services.
The market for coach travel
Supply of regular domestic coach services: KTEL
A.43 Domestic long-distance regular services are operated exclusively by KTEL companies. There are
62 intercity KTEL companies operating 4,230 coaches under a quasi-direct award contract
which provides for strong regulatory intervention by the State. Each of the intercity KTEL
companies is based in a different geographical unit, either a Regional Unit or a large- or
medium-sized island. Most KTEL companies are public limited companies (S.A.), unless they
are very small (with a fleet of 12 or fewer coaches), in which case they remain looser co-
operatives of owner-operators.
A.44 The domestic regular coach services provided by KTEL companies are regulated under Greek
Law 2963/2001 and fall under the exception provided for in Article 8 of Regulation (EC)
1370/2007, for the direct award of contracts for regular intercity public services without
competition. This regime is set to end on 31 December 2019.
A.45 In addition to domestic regular services, KTEL companies can, as an exception, also perform
the following forms of occasional transport:
transport of bathers, where historic rights exist on routes served before Law 2446/1996
applied;
A.61 The new legislation introduces major reforms to the planning, organisation, processes,
contracting and overall provision of public long-distance road transport in Greece. It also
establishes a Regulatory Authority for Passenger Transport (RAEM).
A.62 The market for long-distance coach services will be divided into three segments:
Non-commercial, PSO routes: exclusive rights will be granted to the concessionaire, with
maximum fare and minimum levels of service specified by RAEM, and support from the
State.
Commercial routes: exclusive rights will be granted to the concessionaire, with a
maximum fare and minimum level of service specified by RAEM.
Open routes, not included in the network formed by the above categories, on which the
level of demand is deemed sufficient to allow for full competition: their number is
expected to be limited.
A.63 RAEM will be funded by the industry and will work in close cooperation with the Regional
Units to define criteria for feasibility studies in each Region to assess the segmentation of the
market, manage the tender process and support in the implementation of the liberalised
market. Concessions are expected to be awarded for between eight and ten years, with the
opportunity to extend them by 50%.
A.64 The Federation of KTEL companies, POAYS, notes that it does not agree with the uniform
application across all Member States of Regulation 1370/2007 on domestic intercity and urban
transport, due to the large geographic, economic and social differences between MS. It argues
that State authorities should be able to decide on the most appropriate framework at the local
level, based on these parameters.
Quality initiatives
A.65 The implementation of Greek Law 2963/2001, and the conversion of KTEL companies to public
limited companies in 2003, encouraged system-wide investments into coach fleet renewal and
modernisation of infrastructure such as terminals, ticket offices and “computerisation”. Most
KTEL vehicles are modern, technologically advanced coaches that offer comfortable and safe
services. This capital expenditure has in the main been funded by KTEL shareholders, with
some State funds received from the Public Investment Programme of the Ministry of
Infrastructure, Transport & Networks.
Coach terminals
A.66 Intercity coach terminals are operated by KTEL companies and are either owned or hired by
the companies. International regular routes operated by Greek tourist coaches or
international counterparts are allowed access to these terminals (as defined by article 27 of
Greek Law 4313/2014). New coach terminals have recently been built in Thessaloniki, Larissa,
Trikala, Chalkida, Pyrgos, Lamia, Tripolis and Agrinio.
A.67 A new central intercity coach terminal is also planned for Athens, consolidating the existing
terminals at Kifisos and Liosia into a central terminal at Elleonas, which will be integrated with
the city’s metro system. The indicative budget for the new terminal exceeds €50 million, with
the terminal designed to accommodate approximately 35,000 passengers per day or 12-13
million passengers per annum. However, construction of the new terminal has encountered
numerous delays associated with funding and statutory planning, and press reports indicate
that alternative plans are now being considered.
A.68 Under the planned liberalisation of the market, coach terminals will form part of the national
public transport network and could be operated by any party, subject to licensing and planning
permission. Access to the coach terminals will be available to all operators of domestic and
international services, subject to infrastructure access charges.
Persons with reduced mobility
A.69 As noted above, KTEL companies offer concessionary fares to persons with reduced mobility,
with limited compensation contributed by the State, or with explicit cross-subsidisation
accounted for in the State-defined fare rates.
A.70 Regulation 181/2011 concerning the rights of passengers in bus and coach transport was
transposed into Greek law in 2015, and no records of complaints and infringements, or
analysis of the issues faced in Greece with respect to PRM, are yet available.
Summary of key issues
A.71 Patterns of travel in Greece are heavily influenced by two factors:
Its geography, including the range of islands each requiring their own wholly self-
contained services.
Its markets, with highly seasonal tourist demand in some areas and on many islands.
A.72 Partly for these reasons, long-distance coach services in Greece remain highly regulated. The
State grants exclusive rights to two main categories of operator:
KTEL companies (Joint Receipts Fund of Buses), operating strictly regulated regular
domestic services; and
“tourist coaches”, operating occasional domestic services under looser regulatory
conditions, as well as regular or occasional international services.
A.73 The current arrangements enable the bus and coach sector as a whole to be sufficiently
profitable to invest in vehicles and infrastructure and to cross-subsidise loss-making services in
each area without the need for explicit support. However, the high market value of KTEL
licences suggest that supply, prices, profits and efficiency are not at the levels which would
occur in a more liberalised market.
A.74 This status quo is set to remain in place until the end of 2019, when the new legal and
institutional framework will come into force.
Spain
Regulatory framework
Domestic bus and coach services
A.75 The main law regulating the passenger transport sector in Spain is the Inland Transport
Development Act (Ley de Ordenación de Transportes Terrestres, or LOTT), which originated as
Ley 16/1987 and has been subject to many amendments, with three major ones since 2009:
Ley 25/2009, providing new rules on open access to the market;
Ley 2/2011, the Sustainable Economy Law; and
Ley 9/2013, the new LOTT, updated to acknowledge and regulate the many changes in the
market for road passenger transport at the domestic and at the EU level since 1987.
A.76 The LOTT distinguishes public and private transport services, as shown in Table A.4.
Table A.4: Spain: classification of public and private transport services
Concession are granted for a maximum term of 10 years, with the possibility of extending the
term up to 50% if required to amortise investment needed to provide the service.
Figure A.4: Spain: Autonomous Communities and Provinces
A.81 The competent transport authorities of the Autonomous Communities are responsible for
granting permission to operate regular regional services. In principle, the LOTT allows the
Autonomous Communities to define a procedure for granting access other than a concession,
such as a direct award. However, for historical and economic reasons concessions have been
chosen by all Autonomous Communities, in which access to the concession must be by non-
discriminatory bidding.
A.82 Stakeholders have commented that:
Competition “for the market” is hampered by existing barriers to market access including
the long concession periods, asymmetric information, potential regulatory capture by the
concessionaires, and the preferential treatment of incumbents in new competitions.
In general the requirements to participate in the tenders are low enough as to encourage
entry, but there have been a number of legal controversies concerning the terms of
reference for the bidding of the expired national concessions.
In urban and metropolitan areas, some local authorities maintain a system of direct
administration or systems other than the concession model, such as joint ventures,
transport consortia, or other business models.
A.89 Over 90% of concessions in 2006 had been let by the Autonomous Communities, although
these include both urban and medium-distance intra-community services.
A.90 The majority of concession holders had not changed between 1976 and 2006. However, there
have been more changes in recent years:
60% of the 376 changes in holders of Autonomous Community concessions have occurred
since 2000.
75% of the 28 changes in holders in national concessions have occurred since 2000.
A.91 Data on concession mergers reveals a gradual consolidation between 1976 and 2006.
The practice of term extension
A.92 National and regional concessions are granted for a maximum period of 10 years, with the
possibility of extension by up to half the original term, if required to amortise investments
needed to provide the service. Table A.6 below shows the planned expiry dates of concessions
which were in place in 2007, and Figure A.5 shows how almost all of these concessions should
have expired and been re-let by the end of 2014. In practice this has not been the case.
Table A.6: Spain: planned expiry dates of concessions in place (2007)
1,200
1,000
800
600
400
200
0
2006 2007 2008 2009 2010 2011 2012 2013 2014
Source: Steer Davies Gleave analysis of Comisión Nacional de la Competencia, Informe sobre la competencia en el
transporte interurbano de viajeros en autobús en España, 2008
A.93 Many Communities have recently extended, through various policy instruments, the term of
the concessions of their competence, including:
in 2003, Catalonia;
in 2006, Aragon, La Rioja and Castilla-La Mancha;
in 2007, the Canary Islands and Castilla-León;
in 2008, Asturias, Galicia and Valencia; and
in 2009; Madrid, Murcia, Extremadura, Balearic and (again) Castilla-León and Galicia.
A.94 The Comisión Nacional de la Competencia (CNC) recently expressed an unfavourable opinion
on the Autonomous Communities’ wide practice of extending concessions. In its report, the
CNC disagreed with both:
the philosophy behind these extensions, which contravene the principles and spirit of
Regulation 1370/2007; and
the specific conditions that have accompanied most of them, such as the length of the
extensions and the automatic nature of their enforcement.44
A.95 The extension of regional concessions, generally decreed by specific regional legislative acts,
and often subject to presenting a modernisation plan, is usually claimed to be needed to
improve and modernise the service or to reorder the concession map. CNC argues that:
These plans are generally easy to achieve, making extension almost automatic.
The extensions are often not necessary and proportionate to the quality improvement.
A.96 The CNC argues that, in this period, the wide use term extension have represented a strong
restriction to competition since it has implied the absolute market closure throughout the
time during which the concessions have been extended.
The market for coach travel
A.97 We examined market data and statistics on the size and trends in the coach market, and
examine below the overall market, the interregional market, and the international market.
The market for bus and coach services
A.98 The process of industry concentration from 200 to 2015 is clear in Figure A.6, which shows
how the number of firms with five or more vehicles or more has risen from 44% to 66%.
44
Source: Comisión Nacional de Competencia, Informe sobre las prórrogas de las concesiones
interurbanas de transporte de viajeros en autobús de titularidad autonómica.
Figure A.6: Spain: bus and coach operators by number of authorised vehicles (2000-2015)
A.99 Comparing operator and route numbers in 2000 and at 1 January 2015 shows:
21% fewer operators, from 4,490 to 3,544;
25% more authorised vehicles, from 34,987 to 43,689; and, in consequence
58% more authorised vehicles per operator, from 7.8 to 12.3.
A.100 This concentration process, and the new tender scheme, meaning that competition is open at
both the national and regional level, is entailing changes in the industry structure. In the last
decade there have been at least two major acquisitions by foreign groups: Alsa, operating over
50% of national concessions, has been acquired National Express and Avanza, operating over
10% of national concessions, has been acquired by the Mexican group ADO.
A.101 Figure A.7 shows the distribution of the bus fleet by year of registration. The average age of
the fleet is 13.1 years.
Figure A.7: Spain: distribution of the national bus fleet by registration year
A.102 In 2013, 49% of vehicles were large (over 50 seats), 12% medium (36-50 seats), 23% small (21-
35 seats) and 16% small (fewer than 20 seats).
Volume and supply
A.103 Figure A.8 shows the volume of domestic public transport demand by transport mode. In 2013
the bus and coach sector carried 51,834 million passenger-kilometres or 59% of total domestic
public transport volume.
A.104 The volume of bus and coach passenger-kilometres rose by 37% between 1995 and 2008 and
then fell 15% between 2008 and 2013 after the economic crisis. In comparison, rail passenger-
kilometres grew by 45% between 1995 and 2008 and by 1% between 2008 and 2013, and
domestic air passenger-kilometres grew by 158% between 1995 and an earlier peak, in 2006,
and then by 63% by 2013.
A.105 Figure A.9 shows the proportions of passenger journeys in 2014 by regular, special regular and
occasional coach services.
Figure A.9: Spain: passengers using regular, special regular and occasional coach services (2014)
A.106 As Table A.7 below shows, the number of passenger transported in every bus and coach
market has declined over the five-year period 2009 to 2014.
Table A.7: Spain: bus and coach passengers (million) (2009-2014)
Change
2009 2010 2011 2012 2013 2014 2009-
2014
Urban 1,754.8 1,736.2 1,738.3 1,647.4 1,625.6 1,632.3 -7.0%
Interurban 688.0 678.3 669.6 677.5 663.9 652.0 -5.2%
Suburban areas 465.8 453.3 446.8 457.5 452.7 441.9 -5.1%
Medium distance 202.3 206.2 204.3 201.8 194.4 194.0 -4.1%
Long-distance 19.9 18.9 18.5 18.2 16.8 16.1 -19.0%
Special regular 383.9 361.1 337.6 332.4 347.2 325.3 -15.2%
School transport 281.3 264.1 247.0 244.2 250.4 234.7 -16.5%
Transport of workers 102.6 97.0 90.5 88.2 96.8 90.6 -11.7%
Occasional 185.7 180.1 175.6 158.5 156.3 162.9 -12.3%
Source: INE
A.107 The coach association Confebus stated that passenger numbers have been affected not only
by the economic crisis but also by national rail company RENFE’s aggressive pricing strategy on
long-distance commercial services since 2012. Confebus claims that this caused a consistent
shift to rail by traditional long-distance coach users, the young and the elderly. Coach services
are usually considered inferior goods, which gain market share during an economic downturn.
Figure A.10 shows that this was not the case in Spain between 2010 and 2013.
Figure A.10: Spain: long-distance coach and rail services passengers and GDP (2009-2014)
Source: INE.
A.108 GDP fell by 4%, but long-distance coach volume also fell, while long-distance rail volumes
increased. This supports Confebus’s argument that the divergent trends in long-distance coach
and rail volumes have been driven mainly by the RENFE’s price strategy.
The interregional network
A.109 Regular coach transport crossing the boundaries of Autonomous Communities is regulated by
the Ministry of Public Works and Transport, and broadly corresponds to the market for long-
distance regular services. Figure A.11 shows a map of the network, which is focused on Madrid
and, to a lesser extent, Barcelona and Bilbao.
Source: Centro de estudios y experimentación de obras públicas (CEDEX), reported in Confebus, El transporte en
autocar, una solución sostenible para la movilidad de las personas, 2014.
A.110 Figure A.12 and Tables A.8 to A.12 below summarise indicators of trends on the network.
Figure A.12: Spain: operators and authorised buses (2000-2015)
Firms with authorised buses Number of authorised buses Average buses per firm (secondary axis)
50,000 20
45,000 18
40,000 16
35,000 14
Firms or authorised buses
25,000 10
20,000 8
15,000 6
10,000 4
5,000 2
0 0
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
Year Firms with authorised buses Authorised buses Average buses per firm
2000 4,490 34,987 7.8
2001 4,483 37,424 8.3
2002 4,233 36,929 8.7
2003 4,255 39,343 9.2
2004 4,087 38,801 9.5
2005 4,115 41,229 10.0
2006 3,958 39,808 10.1
2007 3,963 41,745 10.5
2008 3,848 41,463 10.8
2009 3,884 43,966 11.3
2010 3,753 42,449 11.3
2011 3,760 44,467 11.8
2012 3,649 42,559 11.7
2013 3,666 43,828 12.0
2014 3,517 41,666 11.8
2015 3,544 43,689 12.3
A.111 Figure A.12 and Table A.8 above show that, while the number of authorised vehicles has risen
from less than 35,000 to nearly 45,000, the average number of operators has declined
steadily. This means that the average authorised buses per firm has risen from fewer than 8 in
2000 to more than 12 in 2015.
A.112 Table A.9 below shows the decline in the number of interregional concession contracts, which
has fallen by more than 50% since 1993.
Table A.9: Spain: interregional concession contracts (1993-2014)
Year Routes at the start Routes closed Routes transferred Routes opened Routes at the end
of the year to the regions of the year
1993 217 19 68 15 145
1994 145 45 0 37 137
1995 137 32 2 24 127
1996 127 11 0 9 125
1997 125 10 0 7 122
1998 122 7 0 7 122
1999 122 9 0 7 120
2000 120 2 0 2 120
2001 120 3 0 2 119
2002 119 11 0 5 113
2003 113 0 0 0 113
2004 113 4 1 2 110
2005 110 0 0 0 110
2006 110 3 0 1 108
2007 108 0 5 0 103
2008 103 10 0 9 102
2009 102 2 0 3 103
2010 103 3 1 2 101
2011 101 7 0 6 100
2012 100 9 0 4 95
2013 95 6 0 1 90
2014 90 4 0 0 86
Table A.10: Spain: national concessions’ length and number of stops (2000-2014)
Table A.11: Spain: national concessions’ passengers, vehicle- and passenger-kilometres (2000-2014)
Table A.12: Spain: national concessions’ revenues and revenues indicators (2000-2014)
A.113 Table A.13 below compares some of the key data for the tables above for 2000, 2007 and
2014.
Table A.13: Spain: summary of national concessions (2000, 2007 and 2014)
A.114 The total length of national concession routes at the end of 2014 was 75,730 kilometre. The
total number of stops was 4,846, or 3,373 excluding duplication of stops on more than one
line, in 2,897 towns in 2,073 municipalities.
A.115 The overall length of the national concession network rose slightly (2%) between 2000 and
2007 and then fell (-7.7%) between 2007 and 2014, and the total number of stops also fell by
21.9% between 2007 and 2014. Over the same period, the number of national concessions fell
from 145 in 1993, to 120 in 2000 and 86 in 2014, through the process of consolidation into
larger concessions. The average length per concession consequently rose from 671 kilometres
in 2000 to 796 kilometres in 2007 and 881 kilometres in 2014.
A.116 In 2014, 1,193 vehicles were assigned to national concessions, 35.5% of which were equipped
to facilitate access and transport of persons with disabilities or reduced mobility. The average
age of the fleet was 6.6 years with an average of 51.1 seats per vehicle.
A.117 Figure A.13 shows analyses the fleet by size: 67% is large-size vehicles (equal or more than 50
seats), 31% is composed by medium-size vehicles (between 31 and 49 seats) while only 3% of
the fleet is composed by small-size vehicles (30 seats or fewer).
Figure A.13: Spain: coach seating capacity (2014)
Principal operators
A.118 Table A.14 summarises data on operators of national concessions.
Table A.14: Spain: firms and groups of firms operating national concessions (2014)
Percentage of vehicles
(passenger-kilometre)
Passenger-kilometre
Firms in group
Market share
Firm or group
Concessions
(thousands)
(thousands)
(thousands)
Passengers
Vehicles
Alsa 53.6% 2,835,892 12,381 114,702 9 23 392 34% 4.2
Avanza 10.7% 568,216 2,582 27,570 5 10 159 16% 5.0
Samar 6.0% 318,964 4,556 19,071 2 9 181 33% 11.2
Socibus 5.7% 303,418 626 13,571 2 3 35 100% 2.4
Damas 4.2% 224,095 688 6,542 2 4 41 49% 7.5
Bilman Bus 4.1% 215,622 305 6,102 1 1 20 80% 2.2
Monbus 3.1% 161,514 771 9,047 3 5 74 50% 5.8
Jimenez 2.8% 146,472 851 6,586 4 4 42 29% 5.7
Sepulvedana 2.1% 111,858 1,502 6,983 2 2 43 14% 5.8
Bus Madrid-Almeria 1.4% 71,682 129 2,416 1 1 6 100% 3.6
Aisa 1.1% 57,108 1,121 4,233 1 2 50 44% 7.7
Hife 1.0% 53,243 492 4,301 1 2 25 28% 4.4
Dainco 0.9% 45,410 74 2,481 1 1 7 100% 0.6
Leda 0.8% 44,733 757 3,102 1 1 25 8% 6.7
I.R.Bus 0.6% 31,366 840 1,564 2 2 11 91% 3.4
Cevesa 0.6% 29,798 404 4,354 1 4 20 60% 6.8
Linecar 0.3% 16,285 167 1,850 1 1 1 0% 3.6
Therpasa 0.2% 11,654 100 709 1 1 5 0% 7.7
Agreda 0.2% 9,944 147 817 1 1 11 0% 14.2
Costa Azul 0.2% 8,548 230 642 1 1 21 10% 13.2
Miguel Gamon 0.1% 7,630 420 536 1 N/A N/A N/A N/A
Cer 0.1% 7,477 8 579 1 1 6 100% 1.6
Lax 0.1% 3,646 157 241 1 1 7 43% 8.4
Pesa 0.0% 1,267 20 155 1 1 2 0% 13.0
Novatour 0.0% 949 26 135 1 1 5 0% 6.0
Serranica 0.0% 898 11 90 1 1 1 0% 12.9
Molinero 0.0% 873 10 205 1 3 3 67% 7.4
Gzlez y de la riva, SL 0.0% 163 5 52 1 N/A N/A N/A N/A
Total 100% 5,288,727 29,378 238,634 48 86 1,193 35% 6.6
A.119 The market is concentrated, with the three largest groups carrying over 70% of total
passenger-kilometres.
The international transport market
A.120 The international coach market is supervised by the Ministry of Public Works and Transport.
Table A.15 shows the number of Community licences and certified true copies issued between
1999 and 2014.
Table A.15: Spain: Community licences and certified true copies (1999-2014)
A.121 Table A.16 below shows the number of certified true copies per Community licence.
Table A.16: Spain: Community licences and certified true copies (2014)
A.122 The Ministry does not hold data on international regular coach traffic and volumes. In 2014,
the Ministry of Public Works and Transport authorised 35,175 international occasional coach
services within the EU and 688 outside the EU.
Employment
A.123 INE reported that 91,397 people were employed in the bus and coach services sector in
200745.
A.124 In 2014, the coach association Confebus provided its own estimates of direct and indirect
employment in the sector in 2013, shown in Table A.17.
Table A.17: Spain: direct and indirect employment in the bus and coach sector (2013)
Source: Confebus, El transporte en autocar, una solución sostenible para la movilidad de las personas, 2014.
45
We have also identified a report at http://www.fomento.es/NR/rdonlyres/BEA5A540-6C4A-4585-
9A9D-02165C8062ED/128846/OBSERVATORIO_SOCIAL_TRANSPORTE_POR_CARRETERA_2013.pdf.
A.125 Stakeholders reported that working conditions have changed since the entry into force of
Regulation 1073/2009, but that this was due to changes in the economic and labour market,
not to the Regulation itself.
Infrastructure and terminals
A.126 The concession model for coach terminals is a mixed one. Coach terminals are generally
owned by public authorities (municipalities or autonomous communities) which tender their
operation to private companies, although there are also some commercial private terminals.
Table A.18 below provides data on a major terminal, Estación Sur de Autobuses de Madrid, or
Mendez Alvaro terminal.
Table A.18: Spain: Madrid’s Mendez Alvaro terminal
Issue Description
Terminal Estación Sur de Autobuses de Madrid (Mendez Alvaro)
Owner Autonomous Region of Madrid, City of Madrid
Destinations Spain and Europe
Operators Alsa, Avanza, Samar, Arriva Noroeste, Aisa, La Sepulvedana, Cevesa, Eurolines
Capacity 22 bus docks
Passengers 240,000 departures (average 2013/2014)
Left luggage, toilets and baby change, luggage porters, eateries, pay phones, cash
Facilities
machines, bureaux de change, international check-in, hotel booking desk
Location Calle Mendez Alvaro 83, Madrid
Website http://www.estacionautobusesmadrid.com
A.127 The quality of terminals is variable. Major terminals such as Mendez Alvaro are of high quality,
but older terminals often require investment and renewal. The Ministry of Transport has no
direct a responsibility for terminal quality, but recognises that investment in terminals and
interchanges would improve their attractiveness. Coach services only stop outside terminals to
a limited extent, and only by negotiation with the municipalities. Access to coach terminals is
totally open and cannot be denied to operators asking for it. Neither the Public
Administration, nor associations of bus operators and terminals operators, nor the operators
themselves, identified discriminatory barriers to entry46.
Persons with reduced mobility
A.128 The administrations responsible for enforcement of Regulation 181/2011 are the Ministry of
Public Works and Transport and the Transport Departments of the Autonomous Communities,
although the “Ministerio de Sanidad, Políticas Sociales e Igualdad” also has a role through the
“Agencia Española de Consumo, Seguridad Alimentaria y Nutrición” (AECOSAN).
A.129 Only just over one third operating these concessions are yet equipped for the transport of
PRMs, but the issue is not lack of investment. The national concession specifications require
46
Consultations with Confebus (association of bus and coach operators) and the association of
terminals.
that coaches are equipped for PRMs, and fleet renewal will reach the goal of 100% vehicles
equipped for PRMs within concessions tendered under the new terms of reference.
A.130 Most terminals are properly equipped for PRMs. The most common issue mentioned by
stakeholders related to the lack of infrastructures for PRMs in the areas surrounding the
terminals, for which the municipalities are responsible.
France
Introduction
A.131 Until August 2015, the market for long-distance regular coach services in France was strictly
regulated. Long-distance coach services were restricted to cabotage of international services
provided that cabotage traffic remained small, or were operated under public service
contracts.
A.132 In 2015 the market for coach services, with distances between stops of over 100 kilometres,
was deregulated. If stops are within 100 kilometres, the newly appointed independent
regulator must assess whether the services pose an economic threat to existing rail or road
PSO contracts.
Regulatory framework
Background
A.133 Until August 2015, the French regulatory environment was characterised by a history of strict
regulation. The regulatory environment opened up slightly in 2011 as a result of European
Regulation 1073/2009, but it was not until the Macron law47 was passed in July 2015 and
signed in August 2015 that the regulatory environment was significantly relaxed.
Regulatory framework before 2011
A.134 Until 2011, interregional coach services in France could only be operated if one or more of the
following conditions were met:
They were subject to a public transport contract between competent transport
authorities and coach companies. Some services involved only one authority while others
involved more than one.
They were provided as substitutes for regional rail services.
They were operated on lines of “national interest”. This was the case for only three lines
between Roissy-CDG airport and Paris, and between Beauvais airport and the Picardie
region.
A.135 For decades, this framework guaranteed the French incumbent rail operator, SNCF, protection
from intermodal competition from coach services and meant that coach services across France
had a very low market share.
Regulatory framework between 2011 and 2015
A.136 According to article 38 of law no. 2009-1503 of December 2009, between 2011 and 2015
interregional coach services could only be introduced in France in the context of:
Public transport contracts (PSCs), between the competent transport authorities and the
coach companies, as was already the case before 2011.
Cabotage, which enabled international transport companies to provide a certain
proportion of a national service on a route. For instance, a Lille-Paris or Paris-Lyon route
could have been operated under cabotage of an international Brussels-Lyon coach service
47
Law for the growth, activity and equal economic chances
operating via Lille and Paris. The same coach had to be used for the entire route, with no
change of vehicle permitted.
A.137 Additional conditions had to be met by cabotage operations: over a year, domestic passengers
carried through cabotage services could not exceed more than 50% of the passengers, or
contribute more than 50% of the turnover, on any given route. In addition, cabotage
operations were not allowed between stops located within the same region.
A.138 The French Ministry of Transport had three months to approve applications. According to a
2013 study by the French Competition authority48, the Ministry approved about 60% of the
applications it received.
A.139 Decree no. 2010-1388 November 2010, determined the application process and specified the
conditions for authorisation, which was given provided that cabotage services would not
impair the economic balance of PSCs for passenger services by any mode including rail.
However according to the French competition authority (Autorité de la concurrence), the
conditions for granting authorisation were not clearly specified, and decisions to accept or
reject a new coach route often lacked economic justification. In addition, evaluation methods
were not centralised and differed between regions.
A.140 The obligation to form part of an international route resulted in restricting the long-distance
coach services to some parts of the country and some large cities. Turnover restrictions and
limits on the number of passengers also complicated operating activity.
A.141 In 2013, the competition authority recommended the modernisation of the system of
administrative approvals. It highlighted that the lack of transparency was a major problem for
the efficiency of the system and, given that the State is also the main shareholder of SNCF,
called for an independent regulator of the sector.
Regulatory framework before 2015
A.142 The Macron law (July 2015) introduced significant market deregulation. It states that:
Domestic routes on which the distance between two stops is greater than 100 kilometres
are to be liberalised. There is no need for coach operators to go through an approval
process; they will now be able to compete freely with rail services for medium- and long-
distance routes and to set their own fares. The extent of subcontracting permitted
remains unclear, and operators expect clarification from the Government on this point.
Domestic routes on which the distance between two stops is less than 100 kilometres will
require a demonstration that the new coach service will not negatively impact the
economic balance of the PSC for regional rail services.
A.143 The new independent regulator is the Autorité de régulation des activités ferroviaires et
routières (ARAFER), previously known as Autorité de régulation des activités ferroviaires
(ARAF) responsible for rail regulation.
48
“Enquête sectorielle - Transport interregional régulier par autocar”, Autorité de la concurrence,
13 November 2013
49
See http://www.oxera.com/Latest-Thinking/Agenda/2015/En-route-to-French-transport-
liberalisation-the-co.aspx
At a meeting with the Minister of Economy in July 2015, bus operators indicated that they
wanted to open 50 new routes by the end of 2015 and nearly 200 by the end of 2016.
The Ministry of Economy estimated that up to 5 million passengers could opt for this
mode of transport by the end of 2016.
A study commissioned by the French government estimated that there might be a 50%
increase in supply (as with market opening in the UK) and productivity savings of 10%,
resulting in 22,000 direct and other new jobs in the sector by 2025, with further jobs in
the French industrial sector associated with the acquisition of new coaches.
Coach line network
A.151 Specialist website goeuro plotted the map in Figure A.14, which shows the main routes
operated in October 2015, but we note that this information may rapidly become out-of-date.
Figure A.14: France: coach network as at October 2015
A.154 Eurolines is a group of 29 independent private coach companies which began operating in
1985 to create the largest international coach operator in Europe. In France, Belgium,
Netherlands, Poland, Czech Republic, Portugal and Spain, some of Eurolines subsidiary
companies are wholly or partly owned by the Transdev group.
A.155 In France, Transdev has branded its French long-distance coaches as “Isilines” which, from 10
July 10 2015, has operated about 17 national routes interconnecting as many as 50
destinations. Ten of these routes already existed but will be expanded and seven new routes,
such as Nice-Bordeaux-Toulouse have been created. As both brands operate on the French
market, some services will be operated by Eurolines (when domestic services follow
international routes) and others by Isilines. The group's objectives are ambitious; by 2017 it
expects to have 300 coaches able to carry 5 million passengers. This would create 1,000 direct
jobs and a turnover of €100 million.
A.156 Ouibus (formerly iDBUS) the long-distance coach service run by SNCF, launched operations in
2012. It is operated by a subsidiary of SNCF called SNCF-C6 and has a registered capital of €17
million. iDBUS displayed its link with the SNCF Group in different ways; on its coaches, on its
website, in stations. By Dec 2014, iDBUS had carried a million passengers since its launch in
July 2012. It operates 20-25 services to international cities in 7-8 countries and recently began
domestic services to Strasbourg, Nantes and Normandy.
A.157 Starshipper Coach association “Réunir” brings together hundreds of SME coach companies and
provides its members with advisory and other pooled services. The Starshipper brand was
developed for long-distance services along the Rhône river operated by Réunir member Les
Courriers Rhodaniens. Starshipper coaches now provide service to the towns of Rennes,
Nantes, Angers, Le Mans and Lyon from Paris. A Toulouse-San Sebastian line was also opened
in the Southwest, serving Pau, Bayonne, Biarritz and Saint-Jean-de-Luz.
A.158 Megabus is a subsidiary of Stagecoach, one of the most recent entrants into the French
market. Stagecoach announced in May 2015 that it is opening an operational base in the
suburbs of Lyon with 7 based vehicles and the creation of 35 direct jobs. The operator has also
created a new international route: Barcelona-Frankfurt, serving stops in France in Perpignan,
Montpellier, Avignon, Lyon and Mulhouse. More recently Megabus opened a new line
between Milan and London, via Lyon, Paris and Lille. In August 2015, it announced the opening
of an additional route between Brussels, Luxembourg and Strasbourg50.
50
As of February 2016, we understand that Megabus is still expanding its services
A.159 We understand that FlixBus, which, after merging with MeinFernbus, will be the dominant
market player in Germany, is planning to begin operating services in France. It currently
operates some French services through international services (Paris-Maastricht-Antwerp-
Brussels, Germany-Metz-Reims).
Coach terminals
Existing legislative framework
A.160 Coach and bus terminals in France are regulated under a legislative framework dating from
194551, which does not specify the competent authorities in charge of the terminals or
stations. The 1982 Loi d'Orientation des Transports Intérieurs (“LOTI”) stated that coach
terminals are part of the transport infrastructure required for public transport services.
According to the Transport code authorities, there can be a large variety of competent
authorities involved:
the state for services of national interest;
the regions for regional services;
the departments for departmental services; and
the local municipality or group of municipalities, for urban transport services.
A.161 In practice, today it is mainly the departments or municipalities that are the owners of the
coach infrastructure, whatever management model is chosen. A 2012 study by FNTV found
that 44% of coach stations belonged to urban municipalities and 37% to departments. The
remaining owners of coach stations depended on the local situation and included, among
others, private companies, SNCF, and a State-SNCF-department association.
A.162 The transport code leaves the choice of management model of the coach terminals to the
competent authorities. The management can therefore be direct, delegated or under mixed-
management:
Terminals under direct management are managed by an internal operator, under the
direct control of the competent authority.
Terminals under delegated management are managed by an operator appointed by the
competent authority after a competitive tendering procedure.
Terminals under mixed management would be terminals managed by a société
d’économie mixte (SEM), a public-private company with more than 50% of its capital and
voting seats controlled by the competent authority.
A.163 This legislative framework creates significant issues for the industry:
The large variety of ownership structures creates practical problems: some operators
report great difficulties in even identifying the authority in charge of the terminals in
some places.
The term coach “terminal” encompasses different types of infrastructures, from coach
station as commonly understood to a coach stop by the side of the road.
A.164 A large coach operator confirmed that the state of “terminal” infrastructure was highly
variable across France with “very few facilities”.
51
Ordinance from 24 October 1945
52
FNTV website, 05/01/2015, http://www.fntv.fr/transport-par-autocar/autocar-longue-
distance/lignes-nationales/article/lignes-d-autocars-mais-ou-sont-les
A.170 The proximity of coach terminals with railway terminals is also important. On one hand,
railway stations are key intermodal hubs and ensuring that coach terminals are located within
the direct vicinity will support the development of multimodal offers. However, where coach
stations are located by or within the railway station managed in France by SNCF, operators
competing with SNCF’s Ouibus coach services may not always be guaranteed access.
A.171 On quality, the infrastructure available is ill-adapted to long-distance coach transport, with
limited provision of waiting areas, toilets or amenities designed for international transport by
coach which would require larger spaces and higher headroom for international coaches.
A.172 Staffing is also problematic. According to the 2012 FNTV study:
In only 40% of cases are coach terminal staff available throughout the day, from the first
morning departure to the last evening arrival.
In 25% of cases, no staff are available at all during the day, and tickets must be bought
from ticket vending machines or purchased on board services.
Drivers and working conditions in the coach market
A.173 A 2015 report by the French Ministry of Transport53 examined working conditions in the road
passenger market, excluding urban and suburban road transport of passengers54 . We note,
however, that, until summer 2015, at least two-thirds of the road passenger transport
turnover was generated from PSCs between operators and competent authorities, with the
remaining third generated by non-regular services run by private operators. These statistics
provide useful indicators of the coach market in France, but are not specific to the domestic
long-distance regular coach market which barely existed in summer 2015.
Employment trends
A.174 In 2013, the road passenger transport sector employed 94,300 people. The sector grew by
3.2% in 2008 and 3% in 2012.
A.175 Two thirds of the salaried workforce in the sector, representing 61,800 staff, are employed in
the scheduled road transport However, the growth in employment is significantly higher in the
other road passenger transport (7.0% more in 2013 than 2008) that in the regular sector (1.5%
more in 2013 than 2008).
A.176 Drivers represent by far the largest category of staff in both the regular and other road
passenger transport sector, representing 80.2% and 82.3% of total staff respectively.
A.177 The use of temporary staff in road passenger transport in France is low and only represented
1% of the sector’s FTEs in 2013.
A.178 In 2013, the labour movement of employees in road passenger transport in France was stable
at around 30% of leavers and entrants.
A.179 In the sector as a whole, 70% of staff work for businesses with 50 or more staff, and only 5.2%
for businesses with 9 or less staff.
Employment characteristics
A.180 The proportion of part-time workers in the coach market has been increasing since 2006, from
34.2% to 41.4% by 2012. Drivers and other workers more often work part-time in the
chartered coach market than in the regular coach market. In both markets, women are also
more likely to work part-time (51.6% overall) than men (37.9% overall).
A.181 At the end of 2012, the average age of workers in the coach market (both regular and other
services) stood in France at 46.8 years. For drivers it was 47.9 years.
A.182 One in four employees (25.7%) and just over one in five drivers (21.9%) were women in 2012.
53
Commissariat Général au Développement Durable, Bilan social du transport routier de voyageurs.
54
Defined as regular road passenger transport, which includes operation of long-distance coach lines
according to pre-determined schedules, even if seasonal, operation of airport shuttles, operation of
regular school services and other passenger road transport such as tourism trips by coach.
Salaries
A.183 On 1 January 2014, 11% of the road passenger transport staff was paid at the minimum wage
in France.
A.184 In 2012, the average net55 monthly salary in the sector was €1,770. Skilled workers’ (the most
common classification of drivers) average net monthly salary was €1,650. The average net
monthly salary (in full-time equivalent) of employees of the road passenger transport sector
decreased by 3.3% in real terms in 2012, the strongest decline recorded during the last
decade.
A.185 The average net monthly salaries are very close between the regular road passenger transport
sector (€1,820 on average) and the non-scheduled road passenger transport for all
occupational categories (€1,670 on average) with the exception of executives, who were much
better paid in the regular road passenger transport sector.
A.186 The average net hourly wage of part-time employees decreased in 2012, amounting to €9.90
per hour. The hourly wage of part-time employees is 16.8% lower in average than that of full-
time employees, but this gap has reduced slightly since 2007.
Training
A.187 In 2012, the road passenger transport businesses paid 2.1% of their payroll towards training,
the lowest rate since 2008. This rate is significantly lower than that observed in all other
economy sectors.
A.188 In 2012, 35.2% of employees in road passenger transport received training, on average
equivalent to 8.8 hours per employee. Access to training increases with the size of the
company.
Persons with reduced mobility
A.189 The accessibility of coach services by persons with reduced mobility remains variable across
France. Regulation 181/2011 on bus and coach passenger rights provided obligations
regarding persons with reduced mobility, including assistance on board services and in coach
terminals. In France, however, only 11 coach stations56 are able to provide assistance to PRMs:
Paris-Bercy, Bagnolet, Caen, Rouen, Strasbourg, Metz, Angers, Niort, Poitiers, Toulouse and
Aix-en-Provence.
A.190 In addition, a law requiring public spaces to be accessible by 2015 has seen its deadline
extended, after only 40% of public spaces were found to comply. In the transport sector,
urban transport was given a time limit of three years, interurban transport a time limit of six
years and rail services a time limit of nine years.
A.191 Some coach operators offering services in France mention accessible services for PRM, but it
remains unclear whether all coaches are accessible, or the amount of notice that must be
given to operators for the transport of PRM.
55
The net salary is net of any social or pension contributions
56
http://ec.europa.eu/transport/themes/passengers/road/doc/designated_bus_terminals_en.pdf
Coach services
Operator Notice to be given by PRM Assistance available
amenities
Isilines/
Need to contact operator 36 hours
Eurolines Unclear Unclear
before departure
France
100% of coaches for
international
Ouibus services have a Need to contact operator 48 hours Website mentions assistance at
(was iDBUS) dedicated space for before departure at minimum departure and arrival points
one PRM and an
elevated platform
Starshipper Website states that services should be available “in a few months”
Some coaches have
Stagecoach dedicated space for Need to contact operator 48 hours
Unclear
France PRM and an before departure at minimum
elevated platform
FlixBus No information provided on website
A.192 The Macron law does not contain any specific provisions for PRM.
A.193 A large operator commented that demand for PRM services was currently “very low”. This
may be explained by the state of the coach terminal infrastructure (see below) and the
postponement of the law on public space accessibility for PRM.
Summary of key issues
Interpretation of minimum distance between stops of 100 kilometres
A.194 Our discussion with stakeholders has shown that most operators are focusing on services with
a minimum distance of 100 kilometres, where there remains scope for service development.
We assume that operators are keen to build their market, establish their operations and
brand, before looking for opportunities under 100 kilometres.
A.195 One key issue may be access to airports, which are almost always within 100 kilometres of the
main city they serve.
Access to coach terminals
A.196 Operators to whom we spoke reported that it can be difficult to identify the owner or
manager of coach stations in France, and argued that the legislative framework is outdated
and would benefit from an update. OUIBUS (formerly iDBUS), owned by SNCF, has the
advantage that it can use railway stations as coach stations.
Italy
Overview
A.197 Passenger transport by road in Italy is subject to different regulatory regimes, based on the
following classification:
Regular services subject to PSO contracts operated under the provisions of Regulation
1370/2007: these are local (urban and regional) public transport services subject to PSO
contracts which include services of public interest operated on a continuous or periodic
base with fixed itineraries, schedules, frequencies and tariffs, over a regional or sub-
regional territory. Each region sets the process of identifying services subject to PSO, the
level of public compensation needed, and the entities (such as local transport agencies)
responsible for awarding the corresponding contract. The services provided within a
single PSO contract usually cover areas within 50-60 kilometres of a town or city.
Other regular services not subject to PSO that include:
International coach services: these are liberalised and subject to Regulation
1073/2009.
Long-distance national coach services crossing more than two NUTS 2 regions: these
are liberalised and subject to a non-exclusive authorisation regime under national
competence (pursuant to Legislative Decree 285/2005).
Regional coach services within one region or between two NUTS2 regions: these are
liberalised and regulated by regions/local authorities through an authorisation
system.
Occasional services: private coach services carried out on behalf of targeted groups, which
are liberalised and regulated by national Law 218/200357.
A.198 Data from ANAV58 in Table A.21 below shows that the long-distance coach market forms only
3% of the turnover and 2% of the vehicle-kilometres of the total bus and coach sector in Italy.
Table A.21: Italy: bus and coach market indicators (2012)
57
Note, however, that some regions must still pass this national provision in their regional transport act.
58
ANAV is the national coach association representing about 40% of the total bus and coach market and
virtually all long-transport coach operators in Italy.
Regulatory framework
A.199 Authorisation processes to operate regional regular coach services, carried out within two
NUTS2 regions, are defined by regional competent authorities and vary from region to region.
A.200 We describe below the unified national regulatory framework and authorisation process for:
long-distance regular coach services, crossing more than two NUTS2 regions;
international services; and
occasional services.
Domestic regular services
A.201 Before 2005, inter-regional services were operated under a concession regime, which
provided for concession agreements between the operators and the Ministry of Infrastructure
and Transport (MIT). These concessions were exclusive and tended to be renewed
automatically, resulting in no competition either for and within the market.
A.202 Liberalisation took place in two stages. Legislative Decree No. 285/2005 identified MIT as the
competent authority for international coach services and regular interregional services
crossing more than two regions, and the regional authorities as competent authorities for
regional services. The Decree liberalised the interregional coach market, but some of its initial
provisions precluded new entry. More specifically, the Decree established that new
authorisations could not be issued for routes either:
already operated by the previous concessionaires; or
less than 30 kilometres from the old concessions.
A.203 Restrictions in Legislative Decree No. 285/2005 were removed in early 2007 by Decree-Law
No. 7/2007 (converted into Law No. 40/2007), which form the basis for the full liberalisation of
the interregional regular coach services. The new provisions, which entered into force in 2013
after a transition period, allow any operator to enter the market for long-distance
interregional coach services by submitting an authorisation request to MIT.
A.204 Once authorised, services are run on a purely commercial basis. MIT does not specify either
fare levels or routes to be served, but does not offer exclusive rights, and operators compete
with each other.
A.205 The authorisation process, ruled by Article 3 of Legislative Decree No. 285 of 21/11/2005
(“Reorganisation of interregional bus services of national jurisdiction”), is intended only to
verify that the operators comply with technical, financial and legal requirements.
A.206 For long-distance regular domestic coach services, the process has two stages:
First, the applicant submits a request to the technical department of MIT in the capital city
of the Region where the applicant is registered (referred to below as “the MIT regional
office”), which must approve the schedules and routes of the proposed service. This first
phase is completely computerised.
Second, a paper application is submitted to MIT, which verifies its compliance with the
requirements specified in Art. 3, Par. 2 of Legislative Decree No. 285/2005 and others
provided for by law, including:
absence of sanctions of a certain gravity repeated over time;
absence of disqualification by the Anti-Mafia discipline;
presence of Quality Certification;
management consistency of the company (that is, the adequacy of equipment and
personnel to operate the service), verified by the MIT regional office;
accounting separation from services subject to PSO; and
absence of “cherry picking” (where new entrants takes profitable passenger flows
from existing PSO services, worsening their financial position).
A.207 On cherry-picking, the Italian legislative framework59 restricts the verification of cherry picking
only to the cases where the new service runs along the same route and operate over the same
days of an existing profitable service. In these cases MIT identifies whether there is an issue of
cherry picking and then decides whether to authorise the new service. In practice, very few
cherry-picking cases have been assessed by MIT, because the test is avoided if operators
propose slightly different routes or stops from existing routes.
A.208 On successful application, and payment of a contribution, the MIT regional office issues the
authorisation. A paper copy of the authorisation must be kept on board each coach.
International regular services
A.209 The authorisation process for regular international coach services within the EU is as follows:
The company submits an application in the format required by MIT Regulation EC No.
361/2014 to Division No. 2, including all documentation required by Regulation
1073/2009 and MIT circular No. 8/2004, including:
with reference to the proposed route, clearance issued by the MIT regional office;
a declaration of suitability verified and certified by the MIT regional office; and
tables describing driving times, timetables, prices and a map of the route60.
The authorisation request is then passed to MIT Division No. 2 which verifies if the
operator is able to perform the service (through an investigation from its peripheral office
located in the capital city of the Region where the company is established) and, if so,
submits a formal request for Agreement to the Member States affected by the service
proposed.
If agreed by the Member States, MIT Division No. 2 issues the authorisation, consisting of
paper documentation in the format required by Regulation 361/2014, a copy of which has
to be carried on board each coach.
A.210 MIT identified some flaws in the existing EU legislative framework and procedures to operate
international coach services in the EU. In particular, they suggested clarifying how the Member
State managing the authorisation process should deal with responses received by other
Member States that raise concerns or highlight issues with the proposed service which are
outside the grounds for refusal in Article 8(4) of Regulation 1073/2009. MIT stressed that it
would be useful to consider more uniformity on the procedure and processing times for these
observations.
59
Art. 3 of Ministry of Transport Decree No. 316/2006.
60
Quality Certification is required for domestic services but not for international services in the EU.
61
Occasional services are defined (by Art. 2, Par. 2 of Law 218/2003) as “services of carriage of
passengers by a professional company for one or more trips requested by third party contractors or
offered directly to preformed groups, with prior definition of the period of execution, duration and the
total amount due for the use and engagement of the bus, to be paid jointly or be split between the
individual members of the group”.
A.218 For example, in March 2015 AGCM contested a draft of a new proposed regulatory framework
in Regione Campania regarding commercial coach services, in which the Region allowed the
authorisation of regional long-distance commercial services to be refused if there was
“significant” overlap with services subject to PSO. AGCM claimed that such a criteria is was too
discretionary and might allow discriminatory practices in favour of operators of PSO
contracts62.
A.219 In addition, on a number of occasions AGCM has intervened to grant fair competition between
occasional tourist services and regular bus services subject to PSO. Examples include:
points made by AGCM on the draft of a new proposed regulatory framework issued by
Province of Rome regarding access to the market to occasional tourist service63; and
claims raised against the Municipality of Venice that ended into a recourse to court64.
The market for coach travel
Domestic regular market
A.220 In a 2011 study, P. Beria, R. Grimaldi and A. Laurino constructed a geographical database of
the supply of regular long-distance coach services in Italy, based on the data provided by 42
members of ANAV, representing the vast majority of Italian coach operators. They estimated
overall 2010 supply at about 90 million vehicle-kilometres which, assuming an average load
factor of 30 passengers per vehicle, suggested a volume of approximately 3 billion passenger-
kilometres. Private coach operators were found to be generally medium to small-sized:
Only four firms produced more than 6 million vehicle-kilometres per year.
Only seven firms produced between 2 million and 6 million vehicle-kilometres per year.
A.221 This study was updated in 2013 using data for 2012 and, correcting for some inaccuracies
found in the 2011 analysis, concluded that supply was 87.9 million vehicle-kilometres and
volume was 2,600 million passenger-kilometres. However, comparison of the 2011 and 2013
studies revealed increased concentration in the industry. While the output had remained
almost unchanged, output by the major market players had increased consistently between
2010 and 2012. This process of concentration is also confirmed by data provided by MIT. Data
in the 2011-2012 and 2012-2013 statistical reports65 indicate a 25% fall in the number of
operators between 2012 and 2011, and that 54% of all operators are based in the southern
regions.
A.222 In general the comparison between 2011 and 2012 figures provided by MIT shows an overall
increase of the vehicle-kilometres operated at the national level (+15%), achieved due to the
strong increase of the service operated by firms based in the northern and central regions of
Italy (respectively, +137% and +168%). The total number of passengers was estimated as being
equal to 6.8 million in 2012 (-3% over 2011) and the number of passenger-kilometres as being
equal to 3,728 million (+9% over 2011).
62
See AGCM AS1196/2015.
63
See AGCM AS1107/2014 and AS1138/2013.
64
See AS1138/2013
65
Conto Nazionale Trasporti.
A.223 These findings appear to be consistent with those reported in the studies by P. Beria, R.
Grimaldi and A. Laurino, and confirm a trend towards concentration in the industry.
Comparison of 2011 and 2012 shows a 25% fall in the number of firms, mostly in the centre
and south, a 10% rise in fleet size, a 15% rise in output, a 12% rise in average journey length
and a 9% rise in passenger-kilometres.
Table A.22: Italy: long-distance domestic coach services (2011)
Number of passengers
Number of employees
Passenger-kilometres
Number of vehicles
Mileage (thousand
Number of firms
Length of routes
Year Territorial area
(kilometres)
kilometres)
(thousand)
(million)
2011 Northern Italy 39 161 209 31,418 6,265 605 213
Central Italy 31 106 139 15,169 7,383 742 246
Southern Italy and Islands 88 647 1,684 173,696 113,889 5,693 2,971
Total 158 914 2,033 220,283 127,536 7,040 3,431
2012 Northern Italy 33 134 172 35,598 14,821 627 466
Central Italy 22 124 338 29,137 19,759 1,120 652
Southern Italy and Islands 64 746 1,527 221,631 111,848 5,079 2,611
Total 119 1,004 2,037 286,366 146,428 6,826 3,728
Change Northern Italy -15% -17% -18% 13% 137% 4% 118%
2011 to
Central Italy -29% 17% 143% 92% 168% 51% 165%
2012
Southern Italy and Islands -27% 15% -9% 28% -2% -11% -12%
Total -25% 10% 0% 30% 15% -3% 9%
Source: Ministry for Infrastructure and Transport, Conto Nazionale delle Infrastrutture e dei Trasporti, 2012-
2013,editions 2011-2012 and 2012-2013.
A.224 Tables A.23 and A.24 below show that the majority of operators are micro and small
enterprises, with fewer than 3 vehicles and 10 employees. In 2012, only 8 operators owned
more than 20 vehicles and only 20 had more than 20 employees.
Table A.23: Italy: firms operating domestic coach services, by vehicles (2012)
Source: Ministry for Infrastructure and Transport, Conto Nazionale delle Infrastrutture e dei Trasporti, 2012-2013.
Table A.24: Italy: firms operating domestic coach services, by employees (2012)
Source: Ministry for Infrastructure and Transport, Conto Nazionale delle Infrastrutture e dei Trasporti, 2012-2013.
A.225 A recent study (December 2015) by P. Beria, A. Laurino, A. Bertolin, and R. Grimaldi66 updated
the previous findings with the aim of assessing the market developments in the first year
following the full liberalization of long-distance regular services.
A.226 The comparison of supply in 2013 and 2015 shows an overall increase in terms of number of
routes (from 286 to 380 one-way routes per week) and number of services (from 1,421 one-
way services per week to 1,973). In terms of number of services, almost half of the operators
belonging to ANAV have increased their offer (25% increasing their offer with more than 10
new services per week), 20% have decreased their offer, while one third of them have not
changed it.
A.227 The study highlights a number of recent trends in the market, and in particular, the entry of
two foreign newcomers (Megabus and FlixBus) in the market, with large networks and a high
number of services (in terms of number of services, the newcomers represent the first and
sixth operator in the long-distance regular market).
A.228 The new services provided are different from those traditionally supplied by the Italian
existing operators. The newcomers have entered the intercity segment, with a lower number
of stops, a less widespread network mainly competing with the railway, and services mainly
focused on the Northern towns with extensions to the major towns in the Centre and South.
A.229 The major developments in the market, also because of the entrance of the newcomers, are as
follows:
There has been a significant relative growth of the offer in the North, with the starting of
many new intercity coach services. The new routes are within the North and from North
to the Centre.
There has been a strengthening in the South, where the supply remains more dense and
widespread than elsewhere: liberalisation has not led to a contraction in the South.
Services are both expanding and becoming more specialised. New services include
intercity services directly competing with rail, night services, low cost services, and hub
and spoke networks.
A.230 ANAV claims that the new developments prove that the potential market for long-distance
coach transport in Italy is largely larger than the historical one. ANAV underline, however, that
a number of actions are required by the companies to fully exploit this potential. These are
mainly improvements and innovations in the areas of types of services, business models (such
66
Beria P., Laurino A., Bertolin A., Grimaldi R. (2015), Autolinee statali: gli effetti della riforma. Risultati,
opportunità e criticità dell’apertura del mercato – Studio ANAV 2015
Source: P. Beria, R. Grimaldi and A. Laurino, Il trasporto passeggeri su autobus per le lunghe distanze – Studio 2013,
December 2013.
Source: P. Beria, R. Grimaldi and A. Laurino, Il trasporto passeggeri su autobus per le lunghe distanze – Studio 2013,
December 2013.
Little service within the North of Italy, with almost all services in the north being to
provide connections to the South.
A.233 The distribution of stops also differs:
In the South and on the Adriatic Coast, widespread and in a large number of small towns.
In the Centre and North, coach stops are only found in the major cities and towns.
A.234 In the most recent study (2015) Beria, Laurino, Bertolin, and Grimaldi reported a map of the
new network offered by the foreign newcomers (Megabus and FlixBus), shown in Figure A.18.
Figure A.18: New entrant service (2015)
Source: Beria P., Laurino A., Bertolin A., Grimaldi R. (2015). Autolinee statali: gli effetti della riforma. Risultati,
opportunità e criticità dell’apertura del mercato. Studio ANAV 2015.
A.235 Figure A.19 shows long-distance market share in 2012 (or 2010 when 2012 data not available).
Figure A.19: Italy: long-distance domestic coach operators (2012)
Source: Steer Davies Gleave analysis of P. Beria, A. Debernardi et al. (2013), “Il trasporto passeggeri su autobus per
le lunghe distanze, Studio 2013”, on behalf of ANAV. Data for 2012 (blue) or 2010 (grey).
Note: analysis is limited to members of ANAV who provided data.
A.236 Note that the sample is limited to ANAV members who have provided information to ANAV.
A.237 The five largest operators collectively provide around half the total mileage of the operators in
the sample.
International services
A.238 Table A.25 shows data on regular international coach services from MIT’s statistical report.
Table A.25: Italy: regular international coach services (2012)
Number of vehicles
Mileage (thousand
Number of firms
Length of routes
(kilometres)
kilometres)
passengers
(thousand)
employees
Passenger-
Number of
Number of
Territorial area
kilometres
(million)
Northern Italy 10 22 183 32,725 1,775 273 403
Central Italy 2 4 20 1,923 86 23 29
Southern Italy and Islands 31 110 492 111,325 17,421 540 822
Total 43 136 695 145,973 19,282 837 1,254
Source: Ministry for Infrastructure and Transport, Conto Nazionale delle Infrastrutture e dei Trasporti, 2011-2012.
A.239 However, many more operators are permitted to provide occasional international services.
Figure A.20 below shows that Italian operators hold around 3,000 Community licences and
four to five times as many certified true copies.
Figure A.20: Italy: Community licences and certified true copies (2008-2014)
there is no uniformity in market regulation across the country. In the majority of cases local
municipalities are free to set the regulatory regime:
Florence and Rome have adopted quotas to restrict access to the market to limit impact
on traffic and congestion.
Milan has not established any similar restrictions.
A.241 In a recent publication (Open Bus – un modo alternativo di vedere le città, December 2015),
ANAV provided a number of statistics describing the features of the sector:
56 enterprises operating in almost 40 cities (or routes crossing the territory of more
municipalities);
168 coaches, mainly uncovered;
about 900 employees (drivers and guides/stewards) in peak periods, many of them
women;
annual turnover around € 55 million, of which about 50% is generated by the operators in
Rome alone; and
about 3.2 million passengers transported annually (in the cities of art about 10% of
incoming tourists use city sightseeing buses).
Occasional services
A.242 In 2012 ANAV published figures67 on the market for occasional coach services including:
3,690 firms operated coach rental with drivers.
29,780 coaches were registered, of which 3,182 were school buses.
24,000 people were employed in the sector, of whom 22,000 were drivers.
1.2 billion vehicle-kilometres of services were operated.
€2.0 trillion was total turnover.
A.243 Operators of occasional services were generally individuals or small privately-owned
companies, with an average of 7.2 coaches per firm and an average fleet age of 11.8 years.
Their reported workload was:
48% tourist services;
22% student transport;
14% transport of pilgrims;
5% transport of workers;
5% conference transport; and
6% other.
A.244 52% of services were carried out in four months in spring, March to June, 27% in summer, July
to September, and 21% of services in winter, October to February.
Coach terminals
A.245 There is little discussion and networking activity among coach terminal operators in Italy, and
the features of coach terminals vary widely depending on the attitude of the local
administration and key stakeholders involved in the coach sector. Some coach terminals are
67
ANAV (2012), “Trasporto turistico e noleggio autobus con conducente. Le prospettive di sviluppo”,
Rimini, 19/10/2012
well-integrated within the urban infrastructure network, but others have been forced to locate
outside the city centre to reduce urban congestion and pollution. Different factors have
dictated a number of different models, summarised in Table A.26.
Table A.26: Italy: typical models of terminal operation
A.246 Bologna bus and coach terminal is recognised as good practice. The terminal, owned by
Autostazione di Bologna Srl, a public company owned by the Municipality and the
Metropolitan City of Bologna, provides high quality services including:
24 hour opening;
user assistance and surveillance with security guards;
dynamic areas dedicated to carriers for ticketing and check-in activities;
information system for the dynamic management of bus platforms, to optimise the
positioning of arriving carriers and deal with peak times;
internal regulation concerning the assistance to PRMs.
A.247 For PRMs, the terminal is equipped with:
guidelines on the floor;
acoustic signals to indicate the entrance;
braille plaques at the entrance with a description of the route to the platforms;
braille numbers at the platforms; and
a toll-free number for the blind with destinations and timetables.
A.248 Bologna bus and coach terminal of is equipped with 24 bus platforms. As of November 2015,
there were 81 operators authorised to supply regular services. Table A.27 shows the average
number of services per month by type of service.
Table A.27: Italy: monthly average number of services at Bologna terminal (2014-2015)
A.249 The operator of the coach terminal alleged that some carriers illegally load and unload
passengers in areas other than the terminal, particularly foreign operators of international
services, and has requested that:
A public register of all operators authorised on each route is established at EU level.
A common EU template for licences and authorisations is defined, to facilitate inspection
by competent police forces. (In practice, a model licence is provided in Annex II. to
Regulation 1073/2009, and a model authorisation is provided in Annex IV. to Regulation
361/2014.)
A regulation with rules for coach loading and unloading activities is defined at EU level.
A.250 Table A.28 shows the monthly average number of international services in 2014 and 2015.
Table A.28: Italy: monthly average number of international services at Bologna terminal (2014-2015)
68
Source: www.megabus.com; La Repubblica 16/06/2015
for travel during the summer. The overall number of passengers increased by 10%, with
growth of 31% on the Milan-Naples route and 20% on international routes, in particular to
France, Spain and Germany. The company attributed this growth to the high service quality
offered to users and pattern of extending services into a large number of small communities.
The increase on the Milan-Naples route could, however, also be attributed to the reduced
availability of cheap rail services from Trenitalia after the introduction of high speed rail
services.
A.254 The long-distance market is fully liberalised and compliance with the rules governing fair
competition is effectively monitored by regulatory authorities. Recourse to court for claims of
discriminatory practices appears to be more frequent with services under the competence of
regional governments. This might be partially explained by the fact that regional governments
are also responsible for PSCs, and need to prevent commercial lines from eroding the
economic and financial viability of existing PSCs.
A.255 A key choice for regional governments is the extent to which they include profitable regular
bus and coach services within the framework of PSCs rather than separately. Current
economic and financial constraints limit the resources and cash available to subsidise PSCs,
and keeping profitable local and regional bus and coach regular services within PSO contracts
may be preferred by regional and local competent authorities, as this reduces the amount of
compensation they need to provide to operators.
A.256 Transport operators claim that a further easing of the administrative procedure required to
provide long-distance regular services could reduce their costs and benefit market entering.
The Italian Transport Ministry recently declared in a public conference on the theme that they
are looking closely at this situation and aim to further simplify the procedure, for example by
creating a single contact point within their offices for the requirements falling within their
competences as at present two separate offices, the regional and national departments of the
ministry, are involved.
A.257 As far as occasional services are concerned, ANAV claims that a number of issues worsen the
performance of providers of occasional services, in particular:
The national excise duty on diesel fuel, the second highest in Europe after the UK, is
particularly high when compared to those in force in the neighbouring countries such as
France, Austria, and Slovenia.
The wide range of coach access fees levied by Italian Municipalities to restrict coach
access to city centres, supposedly to reduce congestion and pollution levels, unbalances
competition between transport modes and penalises coach.
The lack of adequate coach parking infrastructure in many Italian cities is unwelcoming to
tourists using this mode of transport.
A.258 ANAV suggests a number of interventions at national and local level to improve the framework
for occasional services, such as:
National excise duty on diesel fuel could be reduced to align it to the EU average.
Access fees could be significantly reduced or abolished in cities that also apply the tourist
tax, a discretionary fee they can apply to those staying in accommodation in their
territory.
Some price discrimination in access fees could be applied, to take account of the service
offered by the municipality, such as parking spaces and real time information on traffic,
and of the type of vehicle used, to incentivise those with lower environmental impacts.
Lithuania
Introduction
A.261 Bus and coach transport in Lithuania is divided into regular, occasional and special services.
A.262 The Road Transport Code, enacted in 1996, is the main piece of regulatory legislation. To
provide a bus or coach services an operator requires authorisation from the relevant local or
national authority. Bus and coach services are usually provided by private operators through a
competitive tendering process. Key statistics include:
367 routes;
43 coach and bus operators, the largest by number of routes being Toks, Kautra, Ecolines,
and Eurolines;
51 terminals; and
just over 1 billion passenger-kilometres in 2014, down from a peak of 1.4 billion
passenger-kilometres in 2007.
Regulation of coach service in Lithuania
A.263 The Road Transport Code of the Republic of Lithuania, the main piece of legislation regulating
coach transport, has been amended 14 times and is currently undergoing further
amendments. It classifies road passenger transport as:
Regular services, which provide carriage for passengers at specified intervals, along
specified routes and according to a timetable and fares set in advance. Regular services
can be classified as:
International services, that carry passengers on a specified route crossing the state
border.
Long-distance services, where passengers are carried through the territories of more
than two municipalities.
Local suburban services within the territory of a municipality, which can be extended
into the territories of two neighbouring municipalities if agreed with the State Road
Transport Inspectorate.
Local urban services within a city.
Occasional services, which carry a predetermined group of passengers on a
predetermined route.
Special services, which provide carriage for special passenger groups, such as employee
shuttle buses or school buses.
A.264 Provision of regular passenger services is subject to authorisation:
International and long-distance domestic services are authorised by the Ministry of
Transport and Communications or the institutions authorised by it.
Local suburban or urban service are authorised by the municipalities, or the offices
authorised by them.
A.265 The Road Transport Code and other pieces of legislation regulating coach transport in
Lithuania are summarised in Table A.29.
A.266 The national government and the municipal institutions are responsible for the provision of
public transport services. Licences for public service contracts are granted to private operators
for a period of 5 years through competitive tendering. Operators that sustain losses on routes
that are not profitable are compensated with public funds. PSCs cover:
The nature of the service to be provided, including routing, standards of operational
continuity and regularity, capacity and quality of service.
The price of the service and details of financial relations between the two parties.
The rules concerning amendment and modification of the contract.
The period of validity of the contract.
Penalties in the event of failure to comply with the contract.
Line authorisation process for long-distance services
A.267 The State Road Transport Inspectorate is the competent authority responsible for the
authorisation of long-distance regular coach services. All municipalities and local road
authorities affected by a requested new service are involved in the of authorisation process.
A.270 The number of authorisations issued to operators running domestic services, journey forms
and certificates issued by the Road Transport Inspectorate is shown in Table A.31 below.
Table A.31: Lithuania: certificates, authorisations and licences issued (2009-2014)
Type Note
2009
2010
2011
2012
2013
2014
69
http://www.vkti.gov.lt/index.php?1225828646
A.272 The tables below contain statistics relating to the operation of bus and coach services in
Lithuania in 2014:
Bus and coach services covered 2,672 million passenger-kilometres.
Coach services covered 1,049 million passenger-kilometres, comprising:
123 million regular international services;
536 million regular domestic services;
59 million regular special services; and
331 million occasional services.
A.273 Total coach passenger-kilometres increased from 0.97 billion in 2000 to 1.4 billion in 2004, and
remained relatively constant at this level until 2007. In the following three years to 2010, total
coach passenger-kilometres fell by 35% to 915 million, apparently due to the global recession,
but volume has been steadily recovering since then.
Figure A.21: Lithuania: bus and coach passenger-kilometres (million) (2000-2014)
international
Total regular
Year
Occasional
Suburban
domestic
Regular
Regular
regular
Special
Urban
Total
Total
2000 48.7 6.7 5.5 12.6 73.5 55.3 106.8 235.7 217.6
2001 50.4 6.4 7.3 12.9 77.0 61.9 121.8 260.8 240.6
2002 53.8 7.7 4.9 15.1 81.5 61.4 142.9 285.8 265.8
2003 58.0 9.6 4.6 14.9 87.1 83.1 148.9 319.1 299.6
2004 59.9 11.9 7.8 76.1 155.7 74.0 152.9 382.5 298.6
2005 60.7 12.9 11.9 31.2 116.8 79.6 187.2 383.6 340.4
2006 74.3 10.8 8.1 28.9 122.2 72.3 155.1 349.6 312.6
2007 75.3 9.5 11.6 24.3 120.6 71.0 131.6 323.2 287.3
2008 57.9 8.7 9.2 22.6 98.4 67.3 118.1 283.7 251.9
2009 54.9 5.8 7.5 16.9 85.1 59.7 107.9 252.7 228.3
2010 52.6 5.9 6.7 22.3 87.5 57.0 101.5 246.0 216.9
2011 54.1 6.0 6.6 23.9 90.7 59.1 102.3 252.1 221.5
2012 54.8 5.7 4.7 27.2 92.3 58.0 96.0 246.3 214.4
2013 55.7 5.7 4.8 29.3 95.5 55.7 96.8 247.9 213.9
2014 56.6 7.9 5.0 30.1 99.7 58.0 97.0 254.6 219.4
international
Total regular
Year
Occasional
Suburban
domestic
Regular
Regular
regular
Special
Urban
Total
Total
2000 13.3 1.1 3.7 1.6 19.7 30.8 207.8 258.3 253.0
2001 12.0 1.0 2.3 1.6 17.0 33.2 190.2 240.4 236.5
2002 12.5 1.1 2.4 1.7 17.8 33.6 213.7 265.0 260.8
2003 12.6 1.0 2.0 1.7 17.3 36.1 228.4 281.8 278.2
2004 12.8 1.1 3.7 2.8 20.4 41.3 236.1 297.8 291.3
2005 12.7 1.0 3.7 2.6 20.0 42.1 243.9 306.0 299.7
2006 12.6 1.2 3.7 3.1 20.6 41.8 249.5 312.0 305.1
2007 13.1 0.6 4.2 2.4 20.3 38.3 259.4 317.9 311.3
2008 11.5 0.4 3.7 2.4 18.1 37.6 261.6 317.3 311.1
2009 9.2 0.3 2.5 2.0 14.0 29.6 222.8 266.3 261.8
2010 8.7 0.3 2.8 2.0 13.8 27.4 227.5 268.7 263.9
2011 9.1 0.3 3.1 2.0 14.5 27.1 233.2 274.8 269.7
2012 8.8 0.3 2.7 2.3 14.1 26.1 234.9 275.1 270.2
2013 9.2 0.3 2.3 2.4 14.2 25.9 258.1 298.2 293.5
2014 9.2 0.4 2.2 2.6 14.4 25.5 281.6 321.5 316.6
international
Total regular
Year
Occasional
Suburban
domestic
Regular
Regular
regular
Special
Urban
Total
Total
2000 544.1 90.7 56.9 278.6 970.4 429.4 866.6 2,266.4 1,930.8
2001 529.5 98.1 70.5 281.2 979.3 544.1 807.6 2,331.0 1,979.3
2002 571.6 125.5 56.0 284.6 1,037.6 474.0 996.4 2,508.0 2,167.4
2003 613.3 122.3 62.0 277.9 1,075.5 468.2 1,038.8 2,582.5 2,242.6
2004 661.2 159.0 144.0 447.2 1,411.4 579.3 1,148.9 3,139.5 2,548.3
2005 688.1 162.2 82.4 435.7 1,368.4 576.8 1,321.9 3,267.1 2,749.0
2006 696.1 178.2 80.4 458.0 1,412.6 574.5 1,295.6 3,282.6 2,744.3
2007 711.8 138.4 114.9 435.8 1,400.8 545.0 1,224.5 3,170.3 2,619.7
2008 646.4 112.0 90.4 374.6 1,223.5 521.8 1,206.8 2,952.1 2,487.0
2009 527.2 83.2 62.2 281.6 954.3 392.8 1,035.1 2,382.3 2,038.4
2010 495.2 81.3 72.0 265.9 914.5 381.0 1,052.4 2,347.9 2,009.9
2011 506.0 77.8 110.9 265.8 960.5 362.3 1,077.7 2,400.5 2,023.8
2012 527.8 64.4 80.2 283.6 956.0 356.7 1,073.9 2,386.6 2,022.8
2013 541.6 70.1 60.5 321.0 993.2 355.6 1,172.6 2,521.4 2,139.9
2014 536.3 122.8 59.0 330.8 1,048.9 356.7 1,266.1 2,671.7 2,281.9
Terminals
A.274 Vilnius is the capital city of Lithuania, a large number of international tourists come to Vilnius
by plane and use coach services to travel throughout Lithuania. Almost all Lithuanian
universities and colleges are located in Vilnius, and many students from other towns reach
Vilnius by coach because it is cheaper, faster and more comfortable than traveling by rail.
A.275 The second largest city of Lithuania is Kaunas, which many coach routes pass through because
of its central location within the country. The Kaunas coach terminal is mainly used by
international tourists, students and commuters.
A.276 The third largest city in Lithuania is Klaipėda, its coach terminal is mainly used by commuters
and tourists and several coach services connect Klaipėda with the seaside towns Nida and
Palanga.
A.277 There are currently 51 coach terminals in Lithuania. The five main terminals are located in
Vilnius, Kaunas, Klaupėda, Šiauliai, and Panevėžys, as shown in Figure A.22 below.
Figure A.22: Lithuania: principal terminals for long-distance routes
A.278 The most important long-distance routes, summarised in Tables A.35 and A.36, are from or to:
Vilnius, with 71 outbound and 95 inbound services; and
Kaunas, with 49 outbound and 64 inbound services.
Table A.35: Lithuania: main routes served from the Vilnius terminal
Table A.36: Lithuania: main routes served from the Kaunas terminal
A.279 Most terminals are operated and controlled by the coach operators. The Kaunas bus terminal
is managed by Kautra, and the Šiauliai bus terminal is operated by Busturas.
A.280 International services can stop anywhere there is a coach stop, and only the start and end
points of international routes must be at the coach terminals. All stops on a route must be
authorised before prior to the starting of the service.
Persons with reduced mobility
A.281 Lithuania has 56,000 persons with reduced mobility (PRM), about 7,400 of them children.70 Of
the 51 terminals, 9 are designated to comply with Regulation 181/2011 (cf. Article No. 12). All
coach terminals have agreements with security services to ensure that coaches can be reached
easily by PRM, who must generally pre-book assistance 48 hours before the scheduled
departure time of their coach.
A.282 The Kaunas terminal is now being modernised, after which it will be fully suitable for PRM
travellers. The Klaipėda terminal, opened in 2009, has been designed to take into account the
needs of PRMs, with features including:
The terminal is built entirely at ground level.
All doors are marked with yellow slashes to help PRMs to find door handles.
There are automatic doors.
There are toilets specifically equipped for PRMs and are wheelchair accessible.
At the coach decks, large numbers have been painted on the floor to help those with
difficulty reading the display screens.
70
http://www.socmin.lt/lt/socialine-integracija/neigaliuju-socialine-integracija/statistika.html
Poland
Introduction
A.283 The Polish long-distance and international coach market has been partially liberalised since
the introduction of the Economic Activity Act in 1988. While there are few regulations specific
to the operation of long-distance coaches, as with other EU Member States there are practical
barriers to operation. To operate a long-distance coach or bus service through Poland or
internationally, an operator must obtain the required operators licences at a national level,
and subsequent permissions to operate within or across different regions. Operators seeking
to establish services internationally must also obtain an international permit as provided for in
Regulation 1073/2009.
History of coach services in Poland
A.284 Until disbanded in 1990, public transport was organised by state-run firms which consisted of
a single national State Road Transport firm (PKS) and three regional companies. PKS was the
main national and international operator and carrier of passengers and freight across all road
transport modes71. The Economic Activity Act in 1988 liberated many market areas, including
the Polish coach market, to competition, which resulted in immediate changes to the structure
of PKS. During the early 1990s restructuring resulted in the once-nationalised PKS organisation
and its regional branches being divided into 233 individual, independent operators. Nearly half
were subsequently privatised72, although the number privatised was fewer than had been
anticipated due to a lack of interest from national and foreign investors.
A.285 In the early 1990s there was little market entry, leaving PKS operators with the largest market
share. Toward the end of the decade the coach market had begun to evolve and competitive
pressures created a more financially challenging environment for the public independent
operators, which resulted in some bankruptcy. New local and regional competition to
independent PKS companies arose from small firms, offering connections along profitable
routes, using small fleets of poorer quality coaches and buses. In many cases competition
came from semi-legal and illegal outfits operating without the necessary licences and permits.
In addition to local and regional competition, these new market entrants offered connections
to neighbouring countries and competed on international routes. At its height it was
estimated that this competition from illegal operators accounted for 80% of the international
coach market share for journeys to/from Poland73.
A.286 Since 2000, the share of ownership of coach operators has moved substantially from public
ownership to private firms as shown in Figure A.23 below. This trend is significant and
71
Didier Van de Velde, “‘Long-distance bus services in Europe: concessions or free market?’: The Future
th
of Interurban Passenger Transport” (paper presented at the 19 International Transport Research
Symposium, Madrid, November, 2009).
72
Taylor, Z and A. Ciechanski, “What Happened to the National Road Carrier in a Post-Communist
Country? The Case of Poland’s State Road Transport”, Transport Reviews, 28, 619-640.
73
Komornicki, T, “The Development if International bus Transport in Central Europe: The Case of
Poland”, ECMT Economic Research Centre Round Table 114, Regular Interurban Coach Services in
Europe, OECD, Paris.
ongoing, with recent further decreases in public ownership from 32.7% in 2013 to 29.9% in
2014 (GUS, 2015).
Figure A.23: Poland: market share ownership of bus transport entities (2000 and 2014)
2000 2014
A.287 In 2011 the Polish government introduced new national laws, consistent with Regulations
1071-1073/2009, to govern national and international road passenger transport operations.
The changes have created a more robust and transparent operational framework with access
to the market based on quality criteria.
Future deregulation
A.288 Implementation of Regulations 1071-1073/2009 has paved the way for further changes to
national law effective from 1 January 2017. From this date the national public transport will be
liberalised further by allowing carriers to operate commercially along all routes in Poland.
Overview of the current market
Domestic services
A.289 Figure A.24 overleaf illustrates the number of passenger-kilometres travelled on non-urban
coach services between 2000 and 201474.
A.290 Additional data collected by the Polish National Statistical Office shows that the total distance
travelled by passengers has been in decline since 2000, with a more pronounced decline in
passenger numbers seen between 2008 and 2013. There has, however, been an increase in
the average length of trips made by coach.
A.291 Demand has stabilised with some modest reversal in its longer-term decline. The number of
passenger-kilometres travelled increased by 7% between 2013-14. Despite this rise in total
distance travelled, the number of journeys made by coach fell by 6%. Between 2013 and 2014,
passenger journeys fell by 8% on regular services and rose by 4% on special regular services.
74
Based on enterprises employing more than 9 persons; excluding urban transport services.
Figure A.24: Poland: passenger-kilometres on non-urban bus and coach services (2000-2014)
International services
A.292 In 2014, coach transport accounted for 60% of the international transport market in Poland.
The Polish General Statistical Office (GUS) reported growth between 2013 and 2014 of 17% in
passenger numbers and 14% in passenger-kilometres. However, the number of regular
international routes serving Poland declined from 111 in 2013 to 90 in 2014 (see Table A.37
below).
A.293 Of international journeys made in 2014, 82% were regular or special regular services and the
remaining 18% as occasional.
A.294 The General Inspectorate of Road Transport report that there are currently 3166 licences to
carry out international coach operations in Poland, 2553 issued to individuals and 613 issued
to commercial companies.
Journeys
State Percentage of
Thousands in 2014 Change (2013=100%)
international journeys
Germany 1,463.2 118% 45%
Czech Republic 360.9 164% 11%
France 317.8 112% 10%
Italy 224.8 108% 7%
Austria 178.9 110% 5%
United Kingdom 154.0 130% 5%
Netherlands 65.0 73% 2%
Spain 55.3 79% 2%
Slovakia 52.8 103% 2%
Belgium 48.1 99% 1%
Lithuania 46.5 160% 1%
Switzerland 42.9 110% 1%
Ukraine 40.5 58% 1%
Norway 39.5 277% 1%
Croatia 31.6 92% 1%
Bulgaria 26.5 98% 1%
Hungary 25.2 116% 1%
Greece 24.9 133% 1%
Sweden 6.7 180% 0%
Denmark 6.0 89% 0%
Belarus 5.3 196% 0%
Montenegro 4.5 98% 0%
Luxembourg 2.5 105% 0%
Latvia 2.2 130% 0%
Others 29.7 130% 1%
Total 3,255.3 117% 100%
Note: definitions for international services may not be additive with other Member States.
A.295 Destinations in Germany and the Czech Republic account for over 50% of all cross-border
journeys, although these may be short cross-border routes serving mainly commuting flows.
A.296 Tables A.38 and A.39 below summarise the number and length of domestic and international
routes by Voivodeship (governorship, or administrative region).
Table A.38: Poland: number of domestic and international routes by Voivodeship (2013-2014)
Total, including
Voivodeship Long-distance Regional International
urban/suburban
Total 2013 16,363 608 2,879 111
Total 2014 15,498 565 2,702 90
Dolnośląskie 1,243 51 163 2
Kujawsko-pomorskie 2,148 46 372 0
Lubelskie 1,218 52 266 6
Lubuskie 743 16 151 0
Łódzkie 865 35 144 0
Małopolskie 252 2 42 4
Mazowiecki 2,390 118 376 19
Opolskie 393 3 49 16
Podkarpackie 674 22 82 2
Podlaskie 642 42 132 14
Świętokrzyskie 411 29 50 0
Warmińsko-mazurskie 759 47 198 10
Wielkopolskie 1,262 21 187 1
Zachodniopomorskie 990 36 263 7
Note: definitions for international services may not be additive with other Member States.
Table A.39: Poland: length of domestic and international routes by Voivodeship (kilometres) (2013-2014)
Total, including
Voivodeship Long-distance Regional International
urban/suburban
Total 2013 838,728 221,272 224,207 150298
Total 2014 788,612 208,461 202,360 119110
Dolnośląskie 61,840 21,673 10,518 1098
Kujawsko-pomorskie 95,689 16,298 25,684 0
Lubelskie 67,412 18,185 17,150 4345
Lubuskie 30,369 5,105 10,666 0
Łódzkie 45,252 12,081 13,225 0
Małopolskie 10,533 495 4,178 5319
Mazowiecki 132,715 42,188 31,553 18136
Opolskie 12,417 507 2814 30433
Podkarpackie 30,999 7,376 6347 7390
Podlaskie 38,793 15,497 9227 18091
Pomorskie 39,455 8,056 10616 0
Śląskie 35,799 11,048 5694 16738
Świętokrzyskie 24,891 11,431 4232 0
Warmińsko-mazurskie 44,345 13,604 13773 13590
Wielkopolskie 54,093 6,954 14359 995
Zachodniopomorskie 64,010 17,963 22324 2975
Note: definitions for international services may not be additive with other Member States.
A.298 To become a road transport operator, the operator or designated person within the company
must obtain a national road operator’s licence. This requirement has been in effect since
December 2011 when the former operator’s permit was replaced the current road operator’s
licence, in line with EU Directive 1071/2009. Both freight and passenger operators must apply
for a National Road Operators Licence in order to operate within the transport profession as
set out in Article 4 of the Polish Road Transport Act.
A.299 The process for applying for a National Road Operators Licence has changed and now includes
three new quality criteria which need to be satisfied in order to obtain a permit:
An applicant for a National Road Operators Licence must be have a Certificate of
Professional Competence (CPC), which can be obtained through offices in Warsaw and
Poznań.
Applicants for a licence must register a headquarters, where accounting, employment and
management documents are stored. This change relates to the requirement of an
operation base equipped with facilities to support services.
Several smaller changes in other areas have affected applications for the Road Haulage
Permit. These include standardising the way in which applicants are screened, for example
audits of financial standing and CPCs.
A.300 The National Road Operators Licence is issued by the General Inspectorate of Road Transport
(GITD) and is sufficient to operate occasional services within the country.
Local, regional and inter-regional regular and special regular services
A.301 In addition to holding national road operator’s licence, individuals or companies wishing to
operate regular or special regular services, must also apply for the relevant permits to operate
within different administrative areas of the country. The authority in which the applicant
resides is where the application must be made.
A.302 Permissions to operate on a local level are generally categorised as:
operated within a county (Powiat); or
operated within a regional administrative area (Województwo).
A.303 To obtain a permit the operator must apply to a senior official within the administrative area
they wish to operate, as summarised in Table A.40 below.
Table A.40: Poland: authorisation bodies for regular and special regular services
A.304 In 2014 approximately 8,000 permits, covering 62,200 vehicles, were issued to regular coach
operators, 5.9% fewer than in 201375. The Ministry of Infrastructure and development
informed us that they had not observed any particular changes since the incorporation of
Regulation 1071/2009 into Polish law.
A.305 Changes to the regulatory system and abolition of permits are due to take place in 2017, and
may be a driver for the decline in permit applications.
International regular, special and special regular services
A.306 The General Inspectorate of Road Transport (GITD) are responsible for issuing and enforcing
Community Licences and well as National Road Operators Licences. Community Licences are
issued for vehicles wishing to operate within the EU however GITD also issue licences for
operations within the Swiss Confederation and members of the European Free Trade
Association.
75
Ministry of Infrastructure and Development – Road transport of goods and people – www.mir.gov.pl
A.307 Application for community licences are completed in accordance with Article 7 of Regulation
361/2014. During the verification of permit applications the applicant may be called to correct
any deficiencies within the documentation. Satisfactorily completed documents are sent to
the Member States on whose territory passengers are picked up or set down as well as the
competent authorities of the Member States whose territories are crossed.
Changes to framework governing national passenger services
A.308 From 1 January 2017, major changes to laws governing regular public transport services in
Poland will come into effect. The laws will change to define three entities within the
organisational and legislative framework:
Public transport organiser: a competent body within local/regional government
responsible for organising public transport on a local/regional scale;
Public transport operator: a company authorised by the public transport organiser to
carry out regular transport services under contract (PSCs); and
Public transport carrier: a company operating regular services along existing or new
public transport routes on a commercial basis.
A.309 The changes are intended to create equal and non-discriminatory access to the occupation of
road transport operator based on quality criteria and the road passenger transport market.
The aim is that administrative barriers to access to the market are removed, and that the rules
provide for equality of parties in respect to scheduled road passenger services.
A.310 Public transport carriers will for the first time be able to operate competing services on
national routes and internationally in those close to border areas. Public transport carriers will
also be able operate as subcontractors to public transport operators under PSCs.
Stations and terminals
A.311 The majority of stations and terminals are owned by private companies, but some of the
infrastructure within these sites belongs to the local regional governments. In some cases
mixed models stations are part publicly and part privately owned. A third model is where the
infrastructure belongs to the national treasury.
Persons with reduced mobility
A.312 Poland has experienced some delay in adopting Regulation 181/2011 into national legislation.
At present Warszawa Zachodnia (Warsaw West) rail and bus station is the only bus terminal
designated to handle passengers with additional access and mobility needs, although it has
not yet been Designated under Article 12 of the Regulation. Implementation of the Regulation
will also create a requirement for operators to adapt vehicles to accommodate PRM but this
will not be put into effect until a network of terminals have been identified and adapted for
passenger’s needs.
A.313 The Polish Ministry of Infrastructure and development reports that no complaints have been
logged with the GITD in relation to disabled access to bus terminals. Development of future
stations and training of station staff and drivers in assisting PRM will allow for further analysis
of this service provision in future.
Romania
Introduction
A.317 Coach services are fully liberalised in Romania. Regular services are awarded through a
tendering procedure, while special regular services and occasional services are operated
subject to the issue of a license.
A.318 Demand for regular coach transport (in terms of passenger-kilometres in intercity and
international transport) has increased by 38% between 2000 and 2014 while demand for
intercity rail has decreased by 57%.
Regulation
A.319 The main legislative act regulating road passenger transport is the “Ordinance of the
Government of Romania no. 27/2011 on road transport” amended by the Emergency
Ordinance no. 11/2013 and Law 109/2014.
A.320 Ordinance no. 27/2011 provides definitions which distinguish between bus and coach in terms
of vehicle specification:
Buses are defined as vehicles with more than 9 seats (including the driver's seat) designed
for passengers seating and standing; and
Coaches are defined as buses with more than 22 seats, designed and equipped only for
passenger seating (transporting people standing is banned) with the provision of a special
space for carrying of long-distance luggage.
A.321 In this legislation road passenger transport is classified as follows:
scheduled services;
special regular services; and
occasional services.
A.322 Access to the road transport market is liberalised based on the principles of non-
discriminatory and free competition. The Transport and Infrastructure Ministry set the
minimum quality standards for the quality of transport services, public interest and road
safety.
A.323 Licenses to operate bus and coach services are issued by the Romanian Road Authority (ARR),
the technical body of the Transport and Infrastructure Ministry (MT). For regular services and
international routes, companies must apply for a route license, also issued by the ARR.
Regular services
A.324 Regular domestic passenger transport services are based on requirements set by the
competent authority (the ARR), which is in charge of issuing route licenses. Road passenger
transport schedules are developed and approved by the competent authority, which is
responsible for coordinating them with timetables for other modes such as rail. Local bodies
are invited to express their opinion in the development of the transport schedule.
A.325 The competent authority is responsible for setting the following public transport rules:
Conditions for conducting road passenger transport regular services, special regular
services and occasional services;
Defining and approving of public transport schedules;
The assignment of routes included in the public transport schedules to operators;
A.333 The busiest routes in Romania are those to and from Bucharest. There are 22 terminals in
Bucharest with a total of about 500,000 departures per year.
A.334 In 2014 there were 44,283 buses and minibuses registered in Romania (9% more than in
2000). The figure below shows the evolution of the number of registered buses and minibuses
in Romania between 1990-2014.
Figure A.26: Romania: registered buses and minibuses (end of the year)
Figure A.27: Romania: passenger journeys on intercity and international transport (1990-2014)
Source: INS
Source: INS
Coach terminals
A.337 There are 88 main terminals in Romania and 294 coach stations. Terminals are owned and run
by private operators. Access is managed by the terminal owner and there is no set process or
regulation relating to access. In theory, owners can deny access based on specific conditions at
each terminal.
A.338 The Brasov coach terminal in Romania is managed and organised by a public and private
partnership (the Brasov municipality financed the construction of the terminal with a total
investment of €2.5 million). The terminal is connected to local transport services, houses a
police station, a guarded parking area for 140 cars, a waiting room for passengers, ticket
offices, an information office, a duty doctor and 30 commercial spaces on two floors (total
surface of 2,200 square meters). We understand that new entrants are enthusiastic about the
Brasov terminal, as the terminal management ensures independence and equal access rights
for all76.
A.339 Table A.41 below summarises information on three major terminals, including destinations
and passengers served, proximity to urban centres, capacity available and quality of facilities.
Persons with reduced mobility
A.340 There are a few terminals with wheelchair access, but there is also no evidence of any coach
operators providing access to wheelchairs.
Identification of issues
A.341 Stakeholders have been reluctant to join the conversation and no relevant data has been
received.
76
Source: “Doubling the use of collective passenger transport by bus and coach – Practical solutions”,
www.busandcoach.travel
Source: autogari.ro
Sweden
Introduction
A.342 In the 1990s, Sweden’s long-distance coach market was gradually opened, although for a while
rail operator SJ had the right to block services competing directly with its commercial railway
network.
A.343 In 2003 Sweden, Denmark, Finland and Norway signed an agreement on abolition of the
journey form when performing occasional service in the Nordic countries.
A.344 In 2010, Sweden passed the Lag om kollektivtrafik (Public Transport Law), referring inter alia to
Regulation 1370/2007, which states that no exclusive rights may be granted for providing
national public coach services. This means that no coach service is currently under a PSO
regime and the market is open to new entry.
A.345 As for international coach transport, in 2012, Sweden passed the Yrkestrafiklag, referring inter
alia to Regulation 1073/2009, which sets out matters such as the means of enforcement
consistent with the Regulation.
Routes
A.346 Many principal coach routes follow the rail and motorway network radiating from Stockholm,
and constrained in part by lakes Mälaren, Vättern and Vänern, as summarised in Table A.42.
Table A.42: Sweden: principal coach corridors from Stockholm
Source: Steer Davies Gleave analysis, see also Figure A.30 overleaf.
Operators
A.347 Sweden’s largest coach brand is Swebus, a subsidiary of Nobina (the Nordic region’s largest
public transport service provider). Swebus and its partners operate a network of coaches
radiating from Stockholm shown in Figure A.29 overleaf. Other operators include:
Flygbussarna, owned by Transdev, which provides coach connections to seven of
Sweden’s larger airports, including Stockholm Arlanda, and a number of ferry ports. Some
Flygbussarna routes also have through-ticketing with Swebus’s network. (Smaller airports
such as Umeå and Luleå are usually served by PSO-supported local bus routes, although
these may be branded as airport services and have special fares.)
Ybuss, based in Sundsvall, which acts as a partner to Swebus on services north to Umeå.
Airshuttle, a new start-up business providing services between Stockholm and Arlanda
Airport.
Figure A.29: Sweden: domestic and international routes provided by Swebus and partner
Source: Swebus (a subsidiary of Nobina), destinations such as Luleå are not shown.
Coach routes
A.348 The most important node in the domestic coach network is the Cityterminalen coach terminal
in central Stockholm. Cityterminalen provided illustrative information on the principal routes,
and the number of operators on them, which we summarise in Figure A.30.
Figure A.30: Sweden: examples of coach services from Stockholm’s Cityterminalen
5
Number of operators on route
0
Norrköping
Romania
Ferry lines
Jönköping
Arlanda airport
Uppsala
Norway
Göteborg
Karlstad
Linköping
Source: Cityterminalen
A.349 A number of coach routes are served by more than one operator, which provides some
competition, particularly where longer-distance routes converge on the E4, E20 and E18 close
to Stockholm, as Figure A.29 suggests.
A focus on Arlanda Airport coach services
A.350 The dynamic nature of the coach services is illustrated by services between Stockholm and
Arlanda Airport. Since before the opening of the Arlanda Express rail link in 1999, coaches
have operated from Cityterminalen with a number of stops en route. Operator Flygbussarna,
now owned by Transdev, raised its fares in stages from 80 Krona to 89 Krona to 99 Krona and
then, in 2010, to 119 Krona. In May 2010, Swebus entered the market with a competing
service charging only 99 Krona, and Flygbussarna responded by restoring its fares to 99 Krona.
Swebus remained in the market until August 2013 but has now left and advertises
Flygbussarna’s airport services as an adjunct to its own interurban services.
A.351 When, in 2014 Flygbussarna raised fares again, to 105 Krona, Airshuttle entered the market
with a 99 Krona fare, which Flygbussarna now matches. Flygbussarna has also added two new
routes to the airport serving a range of suburban stops, as shown in Figure A.31.
Figure A.31: Sweden: Flygbussarna coach services to suburban bus stops in Stockholm
Source: Flygbussarna
A.352 Flygbussarna and Airshuttle now both offer a range of discounted fares and sell tickets from
machines, on board the bus and on the internet.
A.353 As the overall market for travel to the airport grows, the provision of coach services may
expand further, and it may be possible for two dedicated operators to remain in the market.
Operator and passenger statistics
A.354 Trafikanalys has produced reports of operator and passenger statistics, but until 2011 these
related to “Långväga” (long-distance) services and from 2012 they related to Kommersiell
(commercial services, including a small percentage which are partly-funded by competent
local authorities). The change in definition means that no clear time series emerges, and data
on passenger-kilometres appear to be estimated by multiplying all passenger boardings by an
assumed average trip length of approximately 250 kilometres. This is consistent with our
estimate, in our 2009 study for the Commission, that the size of the 2009 (long-distance)
coach market was 920 million passenger-kilometres.
A.355 While we were able to extract, and confirm the internal consistency of, the information shown
in Table A.40 below, we draw attention to the definition change after 2011 and the apparent
reduction in “routes” between 2012 and 2013.
A.356 Note that we estimated the average passengers per seat per service from the ratio of reported
passenger journeys to reported service departures. Except on services with no intermediate
stopping points, this will overstate average load factor, which may be considerably lower.
Table A.43: Sweden: “long-distance” and “commercial” domestic coach data (2008-2013)
Source: Trafikanalys Långväga buss 2011, Kommersiell linjetrafik på väg 2013, service kilometres in Sweden only.
Note: average passengers per seat per service should not be interpreted as an average load factor.
Note: definition of international services may not be additive with other Member States.
Fleet
A.358 Trafikanalys reports77 that 256 vehicles were used for domestic and international services in
2013, compared with 292 in 2012. Vehicle size varied from 8 to over 80 seats, but nearly half
had 51-60 seats, consistent with the average seats per service shown in Tables A.43 and A.44.
70% of the fleet were under 5 years old and only 2% were over 10 years old.
Employment
A.359 We found no data on employment in the coach sector, but note that Nobina reports a total of
171 employees and 48 vehicles in Sweden. This suggests that employment associated with the
national fleet of 256 coaches may be around 900 people.
77
Kommersiell linjetrafik på väg 2013
Source: http://www.stationsinfo.se/station/, coach station websites, Steer Davies Gleave visits and analysis
A.361 Many of Sweden’s main coach terminals are enclosed to provide protection against winter
weather, but details vary:
Stockholm’s Cityterminalen is a full-enclosed complex with a direct escalator link to
Stockholm Central station and the Stockholm T-bana or metro.
At Jönköping, the coach station, serving long-distance, regional and some local buses, is
integrated directly into the railway station, with a common enclosed waiting area and
enclosed walkways to other bus routes.
At Umeå, railway and coach stations are on opposite sides of the road, but the hub of the
local bus network in Vasaplan is approximately 500 metres away.
At Luleå (not shown on Figure A.25) the coach station has an enclosed waiting room with
walkways to open stands. Local buses routes focus on Smedjegatan, approximately 400
metres away, and the limited rail services operate from a station 150 metres away across
a quiet street.
Figure A.32: Sweden: PRM information and routes at Luleå coach station
Source: http://www.stationsinfo.se/station/, PRM routes shown in red, route top right leads to railway station
Identification of issues
A.369 Sweden illustrates a number of issues, including that:
The market is dynamic, with operators changing their services and pricing to seek
competitive advantage.
However, operators also cooperate where appropriate, such as where Swebus advertises
Flygbussarna’s airport services as an adjunct to its own mainly interurban network.
Terminal capacity is not generally a constraint in smaller cities and towns, although the
coach terminal may be at some distance from other local transport facilities, but may
increasingly become an issue in central Stockholm, where expansion of the existing
Cityterminalen would be difficult.
While Sweden has designated three coach terminals where assistance for disabled
persons and persons with reduced mobility shall be provided, PRM appears to be
provided for at the sample of terminals we examined, and the provision of detailed PRM
information and routes in a consistent style appears to be good practice.
United Kingdom
Introduction
A.370 Coach services in the UK were highly regulated under a licensing system between 1930 and
1980, under which operators required a licence issued by Traffic Commissioners (TCs), who
regulated fares and frequencies. Services were liberalised under the provisions of the
Transport Act 1980, since when coach companies have been able to operate regular services
simply by applying for an operating licence. However, London and Northern Ireland represent
two notable exceptions; Transport for London (TfL) is responsible for procuring public
transport services in the capital with whom coach services need to register if they are stopping
in London. Much of the licensing regime in Northern Ireland is run by Translink, an integrated
public transport company.
A.371 Quality controls across the UK are still enforced by the Traffic Commissioners. They are
appointed on a regional basis by the Secretary of State for Transport for the purposes of
granting Public Service Vehicles (PSV) licences, the registration of local bus services and the
implementation of disciplinary action against operators and drivers. They retain the power to
revoke licences for all PSV, including coaches. The Competition and Markets Authority (CMA)
is also notionally responsible for applying the provisions of competition law to this market.
However the CMA has not been involved in any investigations in recent years.
A.372 The first direct impact of deregulation was on market entry. A number of established
companies formed a consortium to compete on the national network with the then
monopolist (the National Bus Company); however this attempt failed over 1981-1983. Levels
of market entry remained high, but so did market exit. New entrants withdrew all services by
the mid-1980s, as a result of fierce competition and the persistence of entry barriers (Jaffer
and Thompson 1986). The NBC was subsequently privatised in 1986 and became National
Express.
A.373 The secondary impacts of deregulation were growth in passenger patronage and a reduction
in fares. However the literature acknowledges that such impacts were short-lived, as
competitors withdrew and National Express built up a dominant position as the single national
long-distance network operator. Other key developments over the last 20 years include
National Express’ divestment of Victoria Coach Station (the largest terminal in the UK) and the
entry of Megabus, described in detail below.
The market for coach travel
Supply of coach services
A.374 The coach market for regular services in the UK is dominated by the incumbent, now a fully
private company, National Express. The company’s share of the regular services market is
estimated to be between 75% and 87%. This range is based on data about passenger numbers
reported in secondary sources78, and on the share of scheduled services departing from
Victoria Coach Station respectively. Operators are not willing to share data on passenger
78
Asintra and Fenebus: El transporte en autocar, una solución sostenible para la movilidad de personas
(2011)
numbers, and this is not published in their annual reports. Revenue figures for 2014 from
annual reports indicate that National Express’ revenue was £275 million (€380 million).
A.375 The busiest routes in the UK (by number of services) are those to and from London, which can
be subdivided into a number of groups, summarised in Table A.46.
Table A.46: UK: major services from London
A.376 The main competitor to National Express on high-volume intercity routes is the new entrant
Megabus, a subsidiary of Stagecoach, one of the largest public transport groups in Britain.
Megabus entered the market in 2003 and has since then operated on key routes alongside the
incumbent. Stagecoach’s annual report states that Megabus’ 2014 revenue was £48 million
(approximately €60 million). Stagecoach also owns a 35% share in Scottish CityLink, the
dominant player in the Scottish market
A.377 Stagecoach also owns the Oxford Tube which, because of features such as the location of the
railway station relative to the city, is able to compete effectively with rail services. Other
operators include Kings Ferry, a subsidiary of National Express, operating mainly on large
commuter markets from London.
A.378 National Express and Megabus offer a range of different services and competition between
the two operators is not simply on price. The main characteristics of the two companies are
summarised in Table A.47.
Source: Steer Davies Gleave analysis of company websites and consultation outputs
A.379 National Express does not, however, face competition from Megabus on services to and from
the largest airports in the country. Here, competition is from specialised companies such as
Greenline (a brand managed by Arriva, which subcontracts some services), Terravision and
easyBus. Around a third of National Express’ business comes from flows to and from airports79,
where market fragmentation results in a different competitive environment from intercity
routes. Competitors tend to be part of, or have commercial agreements with, the major
airlines operating at UK airports.
A.380 Special regular services and occasional services are operated by a number of companies. There
are almost 9,500 licensed operators, of whom 4,500 only own one vehicle, and most own only
two or three vehicles. Occasional services include both domestic private hires for day trips and
international tours, while special regular services include, for example, dedicated services for
sporting and cultural events. Department for Transport statistics provide no data on coaches
after 2010/11, and report a total of 23,800 buses and coaches in 2013/14. From the previous
reported ratio of coaches and buses, we estimate that around 13,000 coach vehicles are
operational in the UK.
A.381 Regular and special regular international services are required to register with the
International Road Freight Office (IRFO), while occasional service require a way bill from the
Confederation of Passenger Transport. Acquiring a licence from the IRFO usually takes 8-10
weeks and the DfT state there have been no unsuccessful applications to date.
79
Interview with National Express
A.382 International services to the rest of Europe are run by a number of companies:
Eurolines is a large consortium providing intercity connections across Europe, with a base
at Victoria Coach Station in London and key destinations including Paris and Amsterdam.
Megabus also operates international connections.
Numerous other companies offer service to Central and Eastern Europe.
The demand for coach travel
Long-distance journeys
A.383 Figure A.33 shows that coach travel has a small market share for journeys between 50 and 250
miles (80-400 kilometres), ranging between 3-5%. Coach market share peaks at 10% for
journeys between 250 and 350 miles (400-560 kilometres), with rail achieving 16% market
share of journeys over the same distance80. For distances over 350 miles (560 kilometres), the
market shares of both coach and rail travel decline rapidly due to competition from air travel.
Figure A.33: UK: mode shares of long-distance trips in England (2009-2013)
A.384 Given that most coach trips are under 150 miles, we estimate that the coach share of the
markets served by both rail and coach is probably around 20-25%.
80
Local buses, non-local buses and private hire buses are all reported as “Bus” in the National Travel
Survey. Given that few or no local buses travel over 50 miles, we assume that these journeys are
coaches.
The majority of passengers choose coach travel because of lower prices. Coach travellers
have higher price elasticities than those using other modes. Other important factors
valued by passengers are convenience, point to point transport, and frequency.
The growth in rail travel over the past decade has not resulted in an erosion of market
shares for coach services. Equally the recession has not had a negative impact, since coach
travel has remained the cheaper alternative for long-distance journeys.
Quality initiatives
A.387 Operators maintained that on-board quality has not changed drastically. In 2003, for example,
the lack of toilets on Megabus coaches was perceived as a deterioration in quality, but in
recent years the service offer has specified as standard services such as hold luggage, WiFi and
charging sockets.
A.388 In recent years, all operators have seen growth in the share of bookings made over the
internet. Paperless services are now available on most coaches, with customers required to
show their booking confirmation code only. Ticketless travel is expected to be more widely
available over the next few years.
A.389 The introduction of Megabus Gold on some lines between London and Scotland has catered
for a small proportion of business customers who look for comfort and safety when travelling
overnight to the capital. The new service introduced in 2013 offers bunk beds, online
entertainment and refreshments.
A.390 Integration with other modes was mentioned as a key area for development by most
operators. National Express and Megabus are both part of a larger groups that run both local
bus services and rail services, affording them the chance to provide more integrated
timetables and ticketing arrangements.
A.391 Further integration at the infrastructure level is sought by all operators. This means increasing
capacity at those existing coach terminals that enjoy the best connectivity with bus and rail
transport, as well as improving facilities at airports.
Coach terminals
A.392 Terminals are owned and run by local authorities or private operators. Access is managed by
the terminal owner and there is no set process or regulation regarding access. Potentially
owners can deny access based on specific conditions at each terminal. The main reasons for
not granting a slot to an operator relate to lack of capacity and/or limitations regarding
specific service characteristics such as night operations or lack of available PRM facilities.
However stakeholders noted that national rules on equal access to terminal facilities, applying
to bus transport, do not apply to coaches, and hence terminal managers have no obligation to
let coaches park at their facilities.
A.393 A review of the information on key terminals, including destinations and passengers served,
proximity to urban centres, capacity available and quality of facilities is summarised in Table
A.48 overleaf.
Persons with reduced mobility
A.394 Only three terminals in the UK are designated for PRM access under regulation 561/2006. At
the time of designation, only London Victoria Coach Station, Birmingham Digbeth and Belfast
Europa Bus Centre were deemed equipped to provide 24-hour services and staff overnight.
The small number of designated terminals results in some operators not being able to offer
services to PRM.
A.395 UK-specific legislation, the Public Service Vehicle Accessibility Regulations 2000 (PSVAR)
requires all local and scheduled services for over 22 people to be wheelchair accessible by 1
January 2020. Most coaches for domestic services already are, though only one wheelchair
space per coach which is pre-bookable81.
A.396 The wheelchair space requirement does not apply to tourist coaches and international
coaches. However, tourist coaches tend not to offer as many facilities for PRM, often on the
basis of cost considerations (operators are wary of the additional mass of lifts, which can be up
to 300 kilograms including attributes). Those operating occasional and international services
face additional issues to accommodate fold out lifts when operating outside terminal facilities.
A.397 Operators also increasingly face requests from the elderly to carry mobility scooters. It is
reasonable to say that the driver is not responsible for breaking up the scooters so that they fit
on board, but no specific rules or code of practice are in place yet regarding mobility scooters.
81
A court ruled in 2014 that operators can ‘request not require’ people to vacate allocated wheelchair
areas for disabled people after a case where mother with a baby refused to move to make way for a
man in a wheelchair.
Identification of issues
A.398 The key market players interviewed for this study have not highlighted any major issues with
the regulatory model adopted in the UK. The main problems mentioned by operators are in
relation to terminal access, and particularly the discretion on the part of terminal owners to
accept, or deny, slots. The instances described by stakeholders appear to relate more to
specific management practices than systemic problems. As part of the works for a new rail line
(Crossrail 2), the landowners at the site where Victoria Coach station is currently located have
signalled their intention to sell the site and relocate the terminal. This is a source of concern
for operators, who foresee some disruption in the following years.
A.399 Some issues are specific to the occasional services operators. For instance, changes brought in
by the Working Time Directive have had the unintended consequence of reducing the
potential pool for part-time drivers, who formerly drove coaches alongside their main work
activity. In addition the introduction of higher charges for a driver Certificate of Professional
Competence (CPC) has been a disincentive for some older drivers who have left the industry.
Concluding remarks
A.400 The UK coach market has been liberalised since the 1980s and competition in the market has
seen both periods of high entry by new operators leading to price wars and greater service
offer, and periods of dominance by the incumbent operator. There is no regulation related to
coach operations. To date, the coach market caters for the movement of specific segments of
the population such as students, young people, international travellers and the elderly. A
differentiated offer has developed over the last decade, with the entry of a new yet large
operator (Megabus) who has consolidated its patronage and turnover over a number of
intercity routes. Various companies compete with the incumbent on routes to and from major
airports, and this segment has seen the highest traffic growth in recent years. Finally British
operators and their subsidiaries are very active on the European market and connect the UK to
numerous destinations in Europe.
Austria
Overview
B.1 The market for long-distance national regular coach services is not liberalised in Austria.
B.2 Domestic legislation distinguishes international and domestic service but does not distinguish
categories of domestic service.
B.3 Most regular domestic coach services are organised within local or regional tariff associations
under PSCs. The procurement process is currently in transition following the implementation
of Regulation 1073/2009. Services are procured by local governments through competitive
tending although older contracts and have not yet been subject to competitive tendering.
B.4 For the last five years, domestic long-distance coach services have been in operation, provided
through concessions granted by the competent authority.
Regulation and market for coach services
B.5 The establishment of regular coach services in Austria generally follows a procurement
process by the relevant local public transport authority, often represented by the respective
tariff association, or the initiative of coach operators.
B.6 In accordance with the Federal act on the organisation of local and regional public passenger
transport (ÖPNRV-G), regular coach services are separated into:
commercial coach services, defined as services whose costs can be fully covered by
income from ticket sales; and
non-commercial services, including all other regular services not meeting these criteria
and acquired under a PSC.
B.7 Non-commercial regular services must now be procured through a competitive tendering
procedure and are regulated in the Federal Act on Regular Bus and Coach Services (KflG).
Market access
B.8 Access for international coach services is regulated by Regulation 1073/2009.
B.9 Access to the domestic coach services is not liberalised. Operators wishing to operate
commercial services must apply to one of the relevant local authorities, at state level, through
which the proposed route passes.
B.10 The Federal Act on Regular Bus and Coach Services (KflG) sets out details of the authorisation
process, which does not distinguish between commercial and non-commercial services. The
application must contain details of the proposed route, the location of the stops and number
of vehicles in operation. The contacted authority then asks all affected parties for their
statements or objections, which are then assessed by the authority. The parties that are
usually consulted include:
coach and rail operators whose service area is affected by the proposed route; and
federal states, municipalities, tariff associations and chambers of commerce.
B.11 Authorisation of the route may be granted if all of the following conditions are met:
The applicant proved its reliability, professional and financial suitability.
The applicant has Austrian nationality and the operating company is based in Austria,
although companies from EU member states are treated as Austrian applicants.
The proposed route satisfies the relevant demand in an appropriate and economically
viable manner.
The proposed route is not in conflict with the public interest, in particular:
Road safety is not compromised by the proposed route.
The demand for existing rail or coach services is not compromised by the proposed
route.
No procurement procedure for a similar non-commercial service has already begun.
The proposed service does not anticipate a service that could be more appropriately
delivered by existing transport operators. In these circumstances, however, the
responsible authority may require an existing operator to provide the necessary
improvement within six months: if this is not done the proposal will be permitted.
B.12 In accordance with the Austrian Administrative Procedure Act, the time limit for processing
applications for domestic route authorisations is six months. This can be extended if the
application is not complete or any affected party brings forward an objection.
Employment
B.13 Employment conditions in the Coach market are generally based on a collective agreement,
agreed and negotiated by the Austrian Chamber of Commerce (WKO), which covers
approximately 95% of all employees in the sector. There is a current shortage of qualified
coach drivers in Austria, which results in operators trying to build positive long-term
relationships with their drivers.
Enforcement
B.14 Every five years, the responsible local authority assesses the requirements for operating a
concession. This includes the level of reliability and technical and financial requirements. The
concession can be withdrawn at any point during or at the end of the five year period if the
requirements are not met.
B.15 The police, sometimes with the Ministry of Transport, carry out on-road checks of compliance
with driving hours’ limits and vehicle safety standards. Compliance with labour regulations is
overseen by the Labour Inspectorate.
Competition and discriminatory practices
B.16 The largest Austrian coach operator is ÖBB Postbus, owned by the Federal Ministry of
Transport. It operates mainly regional services, originally intended as complementary to ÖBB's
rail operations. Most regular ÖBB Postbus services are non-commercial, run under PSCs and,
since implementation of Regulation 1370/2007, are procured through competitive tendering.
B.17 One new entrant in the domestic coach market claimed that competitive tenders are designed
to favour ÖBB Postbus, as services must begin within a short period which can in practice only
be met by ÖBB Postbus.
B.18 In 2010, incumbent rail operator ÖBB ended direct rail services between Graz and Linz, the
second and third largest Austrian cities respectively. Westbus, an Austrian coach operator,
successfully began commercial services between these two cities, but after six months of
operation the Bundesministerium für Verkehr, Innovation und Technologie (BMVIT) put the
route out for competitive tender as a non-commercial PSO service. Westbus claims that this
subsidised non-commercial service is compromising its commercial coach service and that
there is no need for a publicly subsided service when a commercial one is viable.
B.19 Two of the main stakeholders in the Austrian coach market reported concerns that the
incumbent rail operator ÖBB plans a subsidiary to operate regular coach services in Austria.
B.20 The current legal framework was designed to protect existing regular public transport service
concessions from competition, by means of a formal right of the existing operator to file an
objection as part of the route authorisation process. For rail, this meant protection for ÖBB,
the dominant and originally monopoly operator. If ÖBB begins to operate coach services, it will
have the power to permit services by its own subsidiary but not by other operators, leading
prima facie to scope for discrimination.
Infrastructure and terminals
B.21 Arrangements for coach terminals, stations and access to them varies between cities.
Municipalities have powers to authorise the use of bus stops within their area of
responsibility. Authorisations can be refused on the grounds of limited capacity at bus stops or
if a stop would have a negative affect road safety and traffic flow.
Persons with reduced mobility
B.22 In 2006, the Austrian Federal Act on the Equalisation of Persons with Disabilities (BGStG) came
into force, providing general guidance on how infrastructure and public transport vehicles
need to provide accessibility for PRMs, but the Act does not set out any specific requirements
for coaches. Many operators have not equipped all coaches with lifts and wheelchair spaces
for PRMs, but instead identified in the published timetables a number of individual services
that are fully accessible or have assistance provided.
B.23 We understand that the international coach terminal in Vienna, Vienna International
Busterminal (VIB), is the only coach terminal in Austria to comply with provisions of Regulation
181/2011, although it has only recently been designated under Article 12. This terminal is
privately owned by coach operator Blaguss and does not receive any public funding.
Data
B.24 Figure B.1 summarises the total number of passengers carried on bus and coach services.
Almost half were on urban buses, with the remainder roughly equally divided between ÖBB
Postbus and other operators. Less than 1.3% of passengers were on international services.
Figure B.1: Austria: passengers using bus and coach services (2012)
Figure B.2: Austria: passengers using coach services, excluding urban buses (2005-2012)
Figure B.3: Austria: vehicle-kilometres of coach services, excluding urban buses (2005-2012)
Belgium
Introduction
B.25 Responsibility for passenger transport by coach is divided between the federal state (SPF) and
the three regions (Brussels Capital, Flanders and Wallonia). The federal state is responsible for:
international services, such as scheduled international services; and
occasional services.
B.26 Other services, such as scheduled domestic services or specialised scheduled domestic
services, are the responsibility of the regions. However, with no coach services operated under
the responsibility of Brussels Capital, the only two authorities dealing with domestic services,
other than occasional services, are the regions of Flanders and Wallonia.
Regulation and the market for coach services
B.27 There is little evidence of a network of regular coach services in Belgium.
In Flanders, regular coach transport is exclusively organised by De Lijn, the publicly-owned
directly awarded operator of all public transport in the region.
In Wallonia, all regular coach service operations are granted to TEC, the publicly-owned
directly awarded operator of all public transport in the region. This means that, in
practice, an operator wishing to set up a service must subcontract and enter into an
agreement with TEC.
B.28 Both De Lijn and TEC provide services, including school services, under a PSC with their
respective regions. However, neither their annual reports nor those of the regional competent
authorities distinguish bus from coach services or PSCs from commercial operations.
B.29 There are a number of international services, which require a Community licence, which is
issued by the federal ministry. Occasional services exist and also require a Community licence
issued by the federal ministry. The association of Belgian operators informed us that it was not
difficult to obtain a Community licence.
Market access
B.30 The association of Belgian operators told us that there were no particular issues related to
market access by for international services and occasional domestic services. We were
informed that authorisations for international services are typically obtained within a month.
B.31 For domestic regular services, the subcontracting of operators in Flanders is managed via a call
for tender, and will be managed by a call for tenders in Wallonia, to be launched by TEC, in
2019.
Employment
B.32 Employment in the bus and coach sector has grown steadily over the period 2003 to 2009
with, a relative stagnation in 2010. 72% of employment is located in Flanders, with 24% in
Wallonia and 4% in the capital region. There is a clear trend to ageing of workers in the sector:
between 2000 and 2011 the average age rose from 45 to 50. Women represent 11% of the
workers in the sector.
B.33 TEC reported total employment of 5,060 in 2009 and 5,018 in 2014.
Enforcement
B.34 The enforcement authorities are the competent authorities: the SPF (Federal Ministry of
Mobility) for international and occasional services and the two regional authorities (Wallonia
and Flanders) within their boundaries.
Competition and discriminatory practices
B.35 We found no information on competition and discriminatory practices. The association of
Belgian operators did not report any problems related to competition or discriminatory
practices.
Infrastructure and terminals
B.36 Belgium has no network of coach stations. We understand that this derives from the legislative
framework for coach in which the responsibility is divided between three authorities. There
are some points at which passengers can change from bus to metro, or to rail. Coach services,
however, appear not to have been considered to be relevant or granted access to them.
B.37 Bruxelles Gare du Nord has been designated under Article 12 of Regulation 181/2011, but its
services to passengers are very basic:
Eurolines has a small office and a waiting room for its passengers.
No other international operators have any facilities.
Passengers must use SNCB (rail) waiting rooms and other facilities (where available).
Coaches stop in the street.
There is no real-time information on arrival and departure times.
Persons with reduced mobility
B.38 Buses and coaches are becoming more and more accessible, including the provision of
wheelchair lifts on coaches. However, infrastructure provision for PRM is poor and hampers
the development of coach services accessible to PRM.
The impact of Regulation 1073/2009
B.39 TEC informed us that Regulation 1073/2009 had had no effect on the region of Wallonia, and
we did not identify any proposals for changes in Belgian legislation for the coach sector.
B.40 Operators informed us that they have been observing with interest the market opening in
Germany and more recently in France.
Bulgaria
Overview
B.41 The coach market in Bulgaria has been fully liberalised since 1999.
B.42 Long-distance domestic regular coach services are widespread and most long-distance
journeys on public transport are taken by coach. Despite the existence of a well-developed rail
network, train services are slow and of poor quality, and coaches carry many more passengers
than the railways on competing routes.
B.43 International regular coach services are widespread and cover major destinations within the
European Union and Turkey, primarily serving those working or studying abroad. Tourist
services have a significant share of coach services in the Bulgaria, with many routes serving
destinations in neighbouring countries.
Regulation and market for coach services
B.44 International coach services are governed by Regulation 1073/2009.
B.45 As permitted under Article 4 of the Regulation, Community licence are accepted for domestic
transport operations. Domestic coach services are subject to licensing and regulatory regimes,
based on the following classifications:
All coach services were fully liberalised in 1999 and require a licence. Licensing and
regulations since 1999 have been enforced by the Automobile Transport Act and
subsequent acts from 1999 and 2002 have amended the regulation to comply with EU
Regulations 1370/2007 and 1073/2009.
Regular coach services crossing more than one region are subject to an authorisation
regime by the Ministry of Transport, Information Technologies and Communication
(MTITC), in accord with the National Transport Scheme, covering the number of coach
routes and route schedules, and Regulation No. 2 covering public service transport by bus
and coach of MTITC from 2002 as amended.
Regional coach services within one region are authorised by the regional mayor and the
regional governor and are in accord with the Regional Transport Scheme, covering the
number of coach routes and route schedules, and Regulation No. 2 of MTITC from 2002 as
amended for public service transport by bus and coach.
Municipal coach services within one municipality are authorised by the municipal
government and are in accord with the Municipal Transport Scheme , covering the
number of coach routes and route schedules, and Regulation No. 2 of MTITC from 2002 as
amended for public service transport by us and coach.
Special regular services, private charter and occasional services are licensed and regulated
as per Regulation 33 of MTITC from 1999 as amended.
B.46 Regular national long-distance services are licenced by the MTITC. New routes are added or
amended on initiative of the Municipalities with a new routes requested in compliance with
the National Transport Scheme regulation, which are subject to PSOs.
B.47 In 2014, there were 1006 companies with international coach licences, operating 222 regular
international routes, with 47 routes pending approvals.
B.48 In 2013, there were 609 companies with local licences for public transport and 2,777 local
regular coach routes, which cover all cities and major towns in the country.
B.49 National coach route services subject to PSCs are tendered. Routes and schedules are set with
a frequency of 15 minutes on municipal level, 30 minutes on regional and national level and 60
minutes from train schedules.
B.50 Between 2009 and 2013 the volume of travel on regular domestic and international services
rose from 6,931 million passenger-kilometres to 7,527 million passenger-kilometres, but the
number of passengers fell from 112 million to 101 million. These figures do not include private
charter or other occasional services.
Market access
B.51 Access to the national coach market is currently fully liberalised. The liberalisation process was
nearly completed by 2000 and regulation was established by 2002.
B.52 Domestic service operations require licences issued by the MTITC, which verifies compliance
with the National Transport Scheme, which includes a number of financial and operational
adequacy requirements, quality requirements, and other legal requirements. Regional and
municipal coach services require the same licensing procedure and compliance with regional
and municipal transport schemes. Coach services are tendered through PSCs.
B.53 International operations are covered by Regulation 1073/2009, although many international
routes were established before Regulation 1073/2009 came into force.
B.54 Stakeholders reported that the number of coach passengers on long-distance services, and
mainly on international routes, has fallen due to competition from private eight seat
microbuses. These microbuses are not subject to licensing or regulation, and stakeholders
estimated they account for over 30% of total trips.
Employment
B.55 Approval of coach routes by National Transport Scheme includes the provision of the number
of drivers operating on a single trip: most medium and long-distance routes in the country
require 2 drivers for a single trip. International routes require full compliance with Regulation
1073/2009 and on the number of drivers, and drivers’ resting time.
B.56 We found no statistics for the number of employees in the coach market, but an estimate
based on 9,817 bus and coach registrations in 2013 suggests that the total bus and coach
market employment is approximately 50,000.
Enforcement
B.57 The MTITC Executive Agency “Automobile Administration” has cancelled nine passenger
transport licences in 2015. Two of them concerned International coach licences and seven
were local coach licences:
Eight of the cancellations were due to lack of the companies’ financial stability, one of the
main licence requirements. In most cases the companies ceased to operate the route or
no longer had the means to do so.
One cancellation was because a local coach company was non-compliant with driver rest
time requirements.
B.58 An Interviewee from the largest association of coach operators raised a concern with the
legislation, in that an operator can be held responsible for omissions by a driver.
Data
Table B.2: Bulgaria: bus and coach passenger transport (2009-2013)
Source: National Statistical Institute, note that the data are likely to be dominated by bus.
B.65 Figure B.4 and Table B.3 below shows regular domestic and international passenger data.
Figure B.4: Bulgaria: regular domestic and International coach service volumes (2006-2013)
Table B.3: Bulgaria: regular domestic and international long-distance coach services (2006-2013)
Cyprus
Introduction
B.66 Cyprus is an island with no international bus or coach routes. There have been no requests for
Community licences and none have been issued.
B.67 All domestic public transport is by bus and coach, although with a total population of only
around one million, and the fifth highest car ownership rate in the EU (549 per 1000
inhabitants in 2012), there is limited demand for interurban travel.
Regulation and market for coach services
B.68 Bus and coach services in Cyprus are operated by private companies and regulated by the
State. The competent authority and enforcement body is the Road Transport Department of
the Ministry of Transport, Communications and Works. Five staff administer domestic
occasional services.
B.69 Local public transport services are provided through concessions let in each of the five main
cities, and Cyprus has now implemented Regulation 1370/2007.
B.70 Long-distance coach services are provided through a concession let to Intercity Buses, founded
in 2009 with a number of shareholders, which provides all interurban services on the network
described below.
B.71 It has a fleet of 50 large, medium and small coaches, which we understand it intended to
expand to 70 coaches. Under its concession contract, it has an obligation to invest in a
complete fleet management system, automated ticket issuing systems, electronic information
systems for passengers and the creation of smart bus stops.
Figure B.5: Cyprus: coach routes
Origin Destination
Nicosia Paphos
Limassol (Lemesos)
Larnaca
Paralimni (and Agia Napa)
Larnaca Limassol (Lemesos)
Paralimni (and Agia Napa)
Limassol (Lemesos) Paphos
B.72 The formal regulatory framework for long-distance services is unclear, and we were not able
to obtain an interview with the Road Transport Department of the Ministry of Transport,
Communications and Works.
B.73 Airport shuttle services are operated by another company, KAPNOS & Sons Transport Co Ltd
Group, under the brand KAPNOS Airport Shuttle. This claims to be the only scheduled shuttle
network on the island, providing services between Nicosia, Larnaka International Airport and
Paphos Airport on 38 scheduled routes.
Market access
B.74 Access to the coach market can be obtained through a three-step process administered by the
Road Transport Department:
A Certificate of Professional Competence has to be obtained by written examination.
A Road Transport Licence can then be issued.
A supporting licence specifically for Domestic Passenger Transport may then be obtained.
B.75 The administration costs for this process are relatively small.
B.76 Vehicles must comply with the required specifications and standards set at European level.
Employment
B.77 We found no data on employment in the coach industry but estimate from its fleet size that
Intercity Buses may have around 250 employees.
Competition and discriminatory practices
B.78 With a single national concession there is no issue of competition or discriminatory practices.
Infrastructure and terminals
B.79 Provision of terminals in Cyprus is relatively limited. The principal terminal in Nicosia at the
Solomou Square is adjacent to local bus services for Nicosia and provides shade and passenger
information displays but no other facilities.
Persons with reduced mobility
B.80 Cyprus has designated 16 terminals under Article 12 of Regulation (EU) No 181/2011, including
Nicosia Solomou Square. However, these terminals do not include all the stops served by
Intercity Buses, all of which appear to be outdoor stands and many of which appear to be bus
stops shared with local services in urban areas.
B.81 The evidence we saw suggests that Intercity Buses has a modern fleet, and its website states
that it offers a service for people who require mobility and wheelchair assistance, bookable by
ringing its call centre at least 24 hours in advance. We could not, however, confirm whether
Intercity Buses’ fleet is equipped with wheelchair lifts.
B.82 The Tourism Board, advises that persons with reduced mobility should arrange transport in
advance, and provides a list of relevant contacts with specialist providers.
Summary of key issues
B.83 The scale of coach operations on Cyprus is small, and the creation of a single national
concession may conceal cross-subsidy between routes and between busy and quiet seasons.
B.84 The lack of land borders, or even regular vehicle ferry services, acts as a barrier to entry, as
any entrant would need to arrange for its buses to be shipped into the island.
Czech Republic
Overview
B.85 The coach market in the Czech Republic is divided as follows:
International and interurban services are operated by private companies at their own
commercial risk.
Regular regional services subject to PSO are organised and administered by regional
authorities or regional organisers of integrated transport and are tendered to private
operators, typically for 10 years. The majority of public service contracts are tendered but
some directly awarded contracts still exist.
B.86 International services are operated by both:
Czech operators, such as STUDENT AGENCY, Eurolines and Touring Bohemia; and
foreign operators such as MeinFernbus FlixBus, OrangeWays, PolskiBus and other Slovak,
Ukrainian and Bulgarian operators.
B.87 Domestic long-distance interurban services are largely provided by private Czech operators
including STUDENT AGENCY, Probo Bus, Icom, and the ČSAD companies (privatised former
state operators) and some foreign operators, such as Arriva.
Regulation and the market for coach services
B.88 The Czech Ministry of Transport and other transport authorities are responsible for the bus
and coach sector. Other than the Ministry:
Prague city’s authority, authorities of the statutory cities and municipal authorities are
responsible for municipal transport and taxi services.
Regional authorities are responsible in other cases.
B.89 Community licences, valid to operate bus and coach services within the Czech Republic, are
issued by regional transport authorities for regional, long-distance and international services
with no involvement from the Ministry of Transport.
B.90 The provision of coach services is subject to several regulatory regimes.
B.91 International services are governed by Regulation 1073/2009 and Act 111/1994 Coll. and fully
liberalised. Authorisations to operate international services along a specific route are either
granted:
for intra-EU services, by the Ministry of Transport ,or the Ministry of Transport of another
Member State; and
for services outside the EU, by the Ministry of Transport and the competent authorities of
the other states involved.
B.92 All licences are issued for 5 years.
B.94 Fares are set by operators for non-PSO services and by the authority responsible for procuring
PSO services, subject to a regulation issued by the Ministry of Finance setting maximum fares
for all domestic services.
Market access
International regular services
B.95 The market for international transport by coach has been fully liberalised since 1994, although
services crossing Czech national territory can be restricted if competing with existing PSO
contracted services.
Community Licences (Regulation 1073/2009 Article 4) to operate international services
inside the EU, known locally as Eurolicences, can be issued by regional authorities.
Authorisations (Regulation 1073/2009 Chapter III) to operate a specific route are issued by
the Ministry of Transport.
B.96 Article 8 of Chapter III allows four months to issue an authorisation but the Ministry of
Transport reported that these are normally issued within 3 months if there is no fault on the
operator’s side.
Regional regular services
B.97 To operate a regular domestic service operators must have a “Licence to operate regular
passenger transport” (“licence”) from the regional transport authority. The average time
required to obtain a licence is approximately 2 months.
B.98 Licences are awarded independently of PSCs, but may be withheld if a private operator
intends to compete on a commercial basis with PSC services. Commercial services will not be
licenced for routes parallel to either regional railway routes or regional bus/coach routes
subject to PSO contracts.
B.99 Regular regional services are mostly operated under PSCs, most of which were closed to new
tenderers before 2007. Most regions have opened PSCs to competition, but these are still
directly awarded in some regions: these will be opened by 2019, or 2024 in a small number of
exceptional cases.
Occasional services
B.100 To operate domestic occasional services an operator must obtain a Community licence, issued
by a regional transport authority.
Employment
B.101 The number of workers employed in bus and coach transport companies within the Czech
Republic grew by 5% between 2001 and 2010 and there were reported to be 10,107 drivers in
2012. Stakeholders reported that Regulation 1073/2009 had no visible effect on working
conditions.
Enforcement
B.102 The police, the Ministry of Transport and the regional transport authorities are all responsible
for enforcement of the relevant legislation.
B.103 There have been a number of cases of infringement of EU and domestic law by coach
operators, such as provided services without a licence or where unsuitable rolling stock has
been used. One example is the case of Hofmann GmbH and Bohemiatour (a privatised ČSAD
Kíčov company which, following years of declining service was declared bankrupt in 2012).
Competition and discriminatory practices
B.104 We were told by stakeholders that a number of conflicts have arisen in the process of regional
authorities issuing licences, with allegations that incumbent operators were given preference
over market entrants. In addition, some new operators have been refused access to terminal
facilities which, in turn, led to regional authorities rejecting licence applications. For example:
In 2003 the competition authority (ÚOHS) forced ČAS-SERVIS to allow other operators to
enter the bus station in Znojmo because the company misused its monopoly on terminal
facilities.
In the case of STUDENT AGENCY vs ČSAD Liberec, ÚOHS ruled in favour of STUDENT
AGENCY which had been refused access to terminal facilities under the ownership of ČSAD
Liberec. The incumbent incurred a penalty of CZK2.5 million and STUDENT AGENCY access
to the terminal was secured with police assistance in 2005. STUDENT AGENCY is now the
only operator using the terminal facilities in Liberec.
The situation was later repeated between DPML and STUDENT AGENCY, but was resolved
through the provision of a licence by a different regional authority.
B.105 In addition to discriminatory practices regarding access rights, the Czech coach market has also
seen cases of predatory pricing exercised by dominant operators to protect services from
market entrants. As an example, in 2011 Asiana complained that STUDENT AGENCY was
engaging in predatory pricing on the Praha-Brno corridor. In 2014 ÚOHS ruled in favour of
Asiana and fined STUDENT AGENCY CZK5 million, but by then Asiana had exited the market.
Infrastructure and terminals
B.106 The most important coach terminals in the Czech Republic are:
Praha Florenc
Brno Zvonařka
Brno Grand
Ostrava central bus station
B.107 Coach terminals are either owned by municipalities or operators. Following the privatisation of
former nationalised coach operators, extensive old terminal facilities were replaced with
smaller modern terminals. While the quality of these new terminals is generally high, many
terminals suffer from overcrowding with insufficient space for waiting rooms and other
facilities.
B.108 There is no legal provision regulating access to terminals, and access is generally open to all
operators upon payment of a fee. There is anecdotal evidence of complaints and disputes
arising between operators and terminal owners regarding the level of fees.
B.109 Some operators, particularly those from Balkan countries, are using locations other than
terminals to pick-up and set-down passengers. There are no measures regulating the use of
these alternative locations, except that stops cannot be in dangerous places, and cannot be at
motorway service areas.
Persons with reduced mobility
B.110 There are one million people with reduced mobility in the Czech Republic. Bus transport is not
usually barrier free, with the exception of some regional services. Seven terminals have been
designated under Article 12 of Regulation 181/2011:
České Budějovice
Plzeň
Hradec Králové
Olomouc
Ostrava
Brno-Zvonařka
Prague-ÚAN Florenc
The impact of Regulation 1073/2009
B.111 Stakeholders commented that Regulation 1073/2009 has improved overall provision in the
market by allowing cabotage. For example, STUDENT AGENCY can offer a higher quality
service between Praha and Wien and Praha and Bratislava because cabotage is allowed on the
Praha-Brno section.
Data
Table B.6: Czech Republic: passengers and passenger-kilometres (2014)
Denmark
Overview
B.112 The domestic coach market in Denmark is relatively small, in part due to the existence of a
convenient and extensive rail network. Coach services are either regional services planned by
the local authorities or intercity services operated by private companies. Public bus and coach
services carried 356 million passengers in 2015. More passengers statistics are reported in the
Market Data section below.
Regulation and market for coach services
B.113 The Transport Act No. 582/2005 is the main piece of legislation that regulates public transport
in Denmark. The competent authority responsible for overseeing the sector, and issuing
permits to coach operators, is Trafik- og Byggestyrelsen, the Danish Transport and
Construction Agency.
B.114 Most bus and coach services in Denmark are planned and procured by the six regional
transport agencies that are responsible for urban, local and regional bus services. The majority
of coach services are regional services, which connect smaller cities and the countryside to
major cities and train stations.
B.115 Due, in part, to the presence of an extensive rail network, the public intercity coach network is
not well developed, although some private operators run intercity services. These include:
Gråhundbus, who operate long-distance routes within Denmark, to the Danish island of
Bornholm and between Copenhagen and Berlin.
Abildskous Rutebiler, who operate long-distance routes between northern Jutland and
Copenhagen. Other major destinations include Aalborg, Århus, Odense, Roskilde, Viborg,
Randers and Berlin.
Thingaard Express, who operate long-distance services between Fredrikshavn and Esbjerg
in Danish Jutland and provide stops in Aalborg and other cities along the route.
Eurolines, which operate services from over 34 European Countries to Aalborg, Århus,
Copenhagen, Kolding/Falster, Rodby and Vejle.
B.116 Tickets for all publicly operated services can be purchased online at Rejseplanen. Tickets for
privately operated services have to be bought through the operator’s website or at bus
stations.
B.117 There are also companies offering special and private hire services, including Vikingbus,
Edelskov bus and Copenhagen Coach.
Market access
B.118 The Danish Transport and Construction Agency is responsible for issuing both commercial
domestic and international bus and coach licenses. Licences for commercial services are
granted for a period of five years if the route requested by a private operator does not infringe
on an existing public bus service.
B.119 The Danish Transport and Construction Agency confirmed that the entry into force of
Regulation 1073/2009 had required no changes in Denmark. The administration of all
domestic and international coach services and regulations has been carried out by two part-
time employees, both before and after the Regulation came into force.
B.120 The Community licence is accepted for the provision of domestic transport service.
B.121 Regular international services are authorised following the procedure in Regulation
1073/2009. The Danish Transport and Construction Agency has never challenged an
application to competent authorities in another Member State for an authorisation to serve
Denmark. Occasional international services do not require a special permit. Applicants must be
established in Denmark.
Employment
B.122 We found no information on employment in the coach sector in Denmark.
Enforcement
B.123 The Transport Act sets out the rules that operators which hold licences to operate regular
services must adhere to:
the operator must submit regular traffic reports;
the licence holder will continue to operate the route until the authorisation expires;
notice of termination if the operator plans to cease operating the route before the
authorisation expires; and
other agreed terms including routing, timetables and fares.
B.124 The Danish Transport and Construction Agency is responsible for enforcing legislation.
Authorisation can be revoked if the holder has seriously or repeatedly violated the terms of an
authorisation.
Competition and discriminatory practices
B.125 We found no evidence of discriminatory practices in the coach sector in Denmark.
Infrastructure issues
B.126 We found no evidence of infrastructure problems in the coach sector in Denmark.
Passengers with reduced mobility
B.127 The Transport Act states that alternative transport must be provided by transport companies
for passengers of reduced mobility who are unable to use public transport. According to The
Danish Transport and Construction Agency, there were over 957,000 disabled passenger
journeys in 2015.
Market data
Table B.8: Denmark: key data on public bus and coach transport (excluding PRM) (2007-2015)
Total State Grant (million Kr. 2007 Prices) 2,570 3,023 3,287 3,381 3,462 3,448 3,402 3,441 3,544
Roadmap hours ('000s) 9,464 9,459 9,381 9,294 9,068 8,874 8,782 8,861 8,724
Passengers (million) 362 362 346 357 351 354 348 363 356
Estonia
Overview
B.128 In Estonia, all regular bus and coach services (with the exception of international services) are
provided under a concession framework and are thus subject to public service obligations
(PSO). The competent authority regulating and authorising services varies depending on the
nature of the service (such as whether urban and municipal, county, domestic long-distance
and international services).
B.129 Lux Express is the main Estonian coach operator offering domestic and international regular
coach services, connecting Estonia with the other Baltic countries, as well as Germany, Poland,
Netherlands, Russia, Ukraine and other countries. Simple Express is a brand of Lux Express
under which low-cost services are offered. Ecolines Estonia also operates international coach
services under the Latvia-based coach network Ecolines.
B.130 In 2014, almost 150 million passengers were transported by bus and coach in Estonia. Of
them, almost 17 million were transported on county routes, 4.4 million on long-distance
routes, and about 810 thousand on regular international services. In addition, 4.5 million
passenger were transported in non-scheduled domestic transport and about 560 thousand in
non-scheduled international transport, such as tourist charter services. Between 2008 and
2014, passenger-kilometres using county services decreased by about one third; domestic
long-distance routes decreased until 2011 and then recovered ending in 2014 at a level close
to that registered in 2008; international regular passenger-kilometres increased by 3.5 million.
Regulation and market for coach services
B.131 The main national legislation regarding the provision of public road transport in Estonia is the
Public Transport Act, published in 2000.
B.132 With respect to the route length, the Public Transport Act distinguishes two types of service:
Local regular services are for the carriage of passengers by road on rural municipality,
urban or county lines whose route and the points of departure and destination are
located within the administrative territory of the same rural municipality, city or county.
Long-distance regular services are for the carriage of passengers by road on lines whose
points of departure and destination are located in different counties.
B.133 With respect to the nature of transport, the Public Transport act classifies road passenger
transport as follows.
Regular services:
Regular services on the basis of a public service contract (public regular services) are
for the carriage of passengers organised on the basis of a public service contract
agreed by a carrier and a local authority or the state. Passengers may be carried on
the basis of a public service contract on the following lines:
- local bus lines and tram and trolleybus lines; and
- long-distance lines, except international lines.
Commercial regular services are the carriage of passengers organised on the basis of
an authorisation for regular service or contract.
Special regular services (which can be organised on the basis of a public service
contract or on commercial basis) are:
- carriage of workers between home and work;
- carriage of school pupils and students to and from the educational institution;
and
- carriage of military personnel and their families to and from a temporary area of
stationing.
Occasional service are free market services subject to the possession of a Community
license.
Taxi services.
B.134 In the case of public regular services, the carrier is selected on the basis of a public
competition, the conditions of which are established by the party ordering the transport
operation. In addition to the requirements specified in Regulation 1370/2007, the public
service obligation to provide passenger transport services may be imposed on a carrier by a
directly awarded public service contract only if the passenger transport service provided does
not exceed 200,000 vehicle-kilometres per year.
B.135 The competent authorities for regular road passenger transport are:
the rural municipality council or city council for the carriage of passengers by bus, coach,
tram and trolleybus services on a rural or urban route;
the county government for the carriage of passengers by bus and coach on a county
route;
the Road Administration for the carriage of passengers by bus and coach on a domestic
long-distance route; and
the Ministry of Economic Affairs and Communications for the carriage of passengers by
bus and coach on an international long-distance route.
Market access
B.136 The possession of a Community license is required of all operators that wish to provide
domestic and international regular services (on the basis of an authorisation for regular service
or a public service contract) as well as occasional services.
B.137 A carrier holding a Community license is granted an authorisation for regular service by the
following competent authorities:
The rural municipality government or city government in the case of road passenger
transport services on rural municipality or urban lines;
The county government in the case of road passenger transport services on county lines;
The Road Administration in the case of road passenger transport services on long-distance
lines.
B.138 Regular services may be awarded both with and without public competition:
The competent authorities organise a public competition to select the carrier for the
provision of a regular service if:
There is demand for opening a new line;
The carrier’s Community license or authorisation for a regular service has been
revoked;
The carrier refuses to service the line even though there is demand for the service; or
The carrier does not apply for a new authorisation for regular service for a line which
the carrier has hitherto serviced even though there is demand for the service.
A carrier is granted an authorisation for regular service without a public competition if the
carrier:
Applies for the authorisation to service a line to be opened on the carrier’s own
initiative; or
Applies for a new authorisation for regular service to service a line which the carrier
has hitherto serviced.
Employment
B.139 There are no detailed statistics regarding the number of employees working in the regular
long-distance, international, occasional services. There is anecdotal evidence that State laws
and regulations have improved working conditions in recent years.
Enforcement
B.140 A number of public institutions exercise supervision and ensure enforcement of the provisions
of the Public Transport Act:
The rural municipality government or the city government exercises supervision over the
compliance with the requirements of a rural or urban regular service authorisations.
The county government exercises supervision over the compliance with the requirements
of county regular service authorisations and public service contracts awarded, as well as
over those of the authorisation for regular long-distance services passing through the
administrative territory of the county.
The Road Administration exercises supervision over the compliance with the
requirements of long-distance regular service authorisations as well as of international
regular service authorisations granted by the Ministry of Economic Affairs and
Communications.
The Road Administration also exercises supervision over the compliance with the
requirements of public service contracts awarded for long-distance regular services,
county regular services, as well as rural and urban regular services, provided that
subsidies are paid out of the state budget for the public service obligation.
The Ministry of Economic Affairs and Communications exercises supervision over the
compliance with the requirements of international regular service authorisations as well
as public service contracts awarded by it.
The Police and Border Guard Board exercises supervision over documents issued and over
the compliance of public transport vehicles with the requirements upon carriage by road.
The Consumer Protection Board ensures the implementation of Regulation (EC) No
181/2011 upon regular bus and coach services that fall within the scope of the regulation
and exercises supervision over the compliance with the regulation and other
requirements concerning consumer rights.
B.141 All infringements are registered in the Traffic Supervision Data System. Infringements are
entered to the system by Police and Border Guard Board. Infringements of Estonian carriers
made in foreign countries are entered to the system by the Road Administration.
Infringements from other countries (EU Member States) who are members of ERRU are
connected to the Traffic Supervision Data System. Member States that are not members of
ERRU send the information on paper via post and it is then entered to the Traffic Supervision
Data System by Road Administration. Infringements from non-EU states (RU, UA, BY) are sent
and retained on paper, except where the infringement in those countries can be specified
exactly according to the EU infringements system.
Table B.11: Estonia: passenger-kilometres by bus and coach, by type of transport (million) (2008-2014)
Source: Steer Davies Gleave analysis of Road and Railways Department data
Source: Steer Davies Gleave analysis of Road and Railways Department data.
Source: Steer Davies Gleave analysis of Road and Railways Department data.
Source: Steer Davies Gleave analysis of Road and Railways Department data.
Finland
Overview
B.147 Long-distance coach transport is deregulated in Finland. The majority of services are privately
operated; most of which are provided by operators belonging to the Finnish Coach Operators
Association.
B.148 Bus and coach services carried over 350 million passengers in 2013. This represents a market
share of 8.9% across all transport modes. More statistics are reported in the Market Data
section below.
Regulation and market for coach services
B.149 The main legislation regulating bus and coach services in Finland is the Public Transport Act
(869/2009). The competent authorities are the regional Centres of Economic Development,
Transport and the Environment (ELY Centres) and 26 Municipal Authorities, which are
overseen by the Finnish Transport Authority and the Ministry of Transport and
Communications.
B.150 The ELY Centres define the service level of public transport in their area and decide how the
transport services should be administered. Services can be operated commercially or by a
public contract awarded through a tendering process. Public grants are used if the desired
level of service is not reached through commercial operations. Urban bus services are usually
operated through public service contracts while long-distance coach services are mainly
privately operated.
B.151 There are two kinds of intercity bus services:
Regular services (“vakiovuorot”) stopping frequently in smaller towns and villages;
Express services (“pikavuorot”) offering a faster service with limited stops in main cities
and interchanges.
B.152 Express Bus, which is a member of the Finnish Coach Operators Association, operates most of
the coach services in Finland and connects all major towns and cities in the country. Express
Bus has a fleet of over 700 long-distance coaches that provide 2,400 weekly departures and
offers direct connections to Helsinki airport and ports in Helsinki and Turku.
B.153 In 2011 Onnibus, a low-cost operator, entered the market and currently operates 23 routes
most of which start or finish in Helsinki. Unlike Express Bus, Onnibus services do not stop at all
express stops along their route, that reduces end-to-end journey times and which Onnibus
claims makes the business more profitable.
B.154 According to the Finnish Transport Authority, in 2013 the total turnover of long-distance bus
and coach transport was €83 million, and a total subsidy of €6 million was received.
B.155 Finland has an agreement with other Nordic countries, including Estonia, meaning
international trips do not require the travel documentation specified by EU Regulation
1073/2009. As a consequence, the impact of Regulation 1073 is limited to those services
between Finland and non-Nordic countries.
Market access
B.156 The ELY Centres are responsible for the procurement, licencing, planning and funding of road-
based public transport. ELY Centres grant route licences and demand-responsive service
licences to private operators in order to supplement public services. If a route goes through
more than one ELY district, the authorisation is granted by the authority whose district forms
the largest part of the journey.
Employment
B.157 We found no information on employment in the coach sector in Finland.
Enforcement
B.158 We found no information on enforcement in the coach sector in Finland.
Competition and discriminatory practices
B.159 We found no evidence of discriminatory practices in the coach sector in Finland.
Infrastructure issues
B.160 Matkahuolto, an organisation which is part of the Finnish Coach Operators Association,
maintains and operates coach stations in the cities and municipalities around the country. Use
of terminals is not restricted to members of the coach operators association. In addition to
Express Bus, Onnibus uses the main terminal in Helsinki.
B.161 Matkahuolto also offers a parcel delivery service, provides information about coach schedules
and services, and sells tickets at stations. The coach tickets sold at stations are valid on all
Finnish coaches and buses, except for municipal buses of some cities.
B.162 The main coach terminal in Finland is Helsinki bus station located in the Kamppi shopping
centre, with 35 indoor platforms that accommodate roughly 700 arrivals and departures per
day.
Passengers with reduced mobility
B.163 Passengers with reduced mobility traveling on Express Bus services who require assistance are
allowed someone to accompany them free of charge if the journey is over 250 kilometres.
B.164 Onnibus has wheelchair access ramps fitted on its double decker buses, but not on their single
decker coaches.
Market data
Table B.16: Finland: bus and coach market statistics (2003-2013)
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
Passenger-kilometres (million) 4,642 4,663 4,565 4,728 4,731 4,894 4,539 4,814 4,825 4,724 4,737
Vehicle-kilometres (million) 454.2 459.2 457.2 454.4 458.5 463.8 451.1 458.0 452.8 450.5 442.0
Passengers (million) 335.4 326.8 320.7 318.6 319.6 331.4 325.9 339.8 346.8 351.8 352.7
Passengers
Passenger-
kilometres
kilometres
kilometres
Vehicle-
Share
Share
Share
Share
Seat-
Total public transport 1,464 39,486 602 11,698
Collective transport, of which … 705 48% 31,845 81% 542 90% 9,728 83%
Long-distance transport 246 17% 14,675 37% 23 4% 5,036 43%
Railway 164 11% 9,439 24% 14 2% 3,153 27%
Coach 63 4% 3,208 8% 7 1% 623 5%
Air 19 1% 2,029 5% 2 0% 1,260 11%
Collective transport, other than long-
233 16% 6,634 17% 65 11% 1,718 15%
distance and urban transport
Railway 15 1% 1,465 4% 12 2% 484 4%
Bus and coach 97 7% 4,548 12% 40 7% 937 8%
Taxi 121 8% 620 2% 13 2% 297 3%
Charter transport, of which … 759 52% 7,641 19% 60 10% 1,971 17%
Regular charter transport 75 5% 1,174 3% 12 2% 237 2%
Bus and coach 21 1% 900 2% 6 1% 123 1%
Taxi 53 4% 274 1% 5 1% 115 1%
Other charter transport 684 47% 6,467 16% 49 8% 1,734 15%
Bus and coach 77 5% 3,353 8% 11 2% 1,108 10%
Taxi 607 41% 3,114 8% 38 6% 625 5%
Table B.18: Finland: public subsidies to public transport services, € million (2013)
Croatia
Overview
B.165 Croatia became a Member State of the European Union in 2013. At the same time the Road
Transport Act (Zakon o prijevozu u cestovnom prometu) entered into force to regulate
passenger road transport in the country.
B.166 Regular road transport services within the territory of a county (urban transport also comes
under this category) are usually operated (and therefore regulated) by concessions. The Road
Transport Act provides the flexibility that counties (the Competent Authorities in this area) are
free to decide whether to regulate regular road passenger transport within their area on the
basis of concessions; otherwise services are run under an authorisation regime at the request
of the operators. Regular inter-county services are provided under the authority of the
Ministry of Maritime Affairs, Transport and Infrastructure.
B.167 Special and occasional road passenger transport is totally liberalised. Foreign operators in
Croatia have the same conditions in entering the coach market as domestic operators. Access
to the international coach market is fully liberalised in line with EU legislation.
Regulation and market for coach services
B.168 Road passenger transport services operating in Croatia are classified as:
Regular inter-county public passenger transport services, which are run under a national
authorisation regime (licences are issued by the Ministry of Maritime Affairs, Transport
and Infrastructure for a period up to 5 years).
Regular intra-county public passenger transport services, which are authorised by the
county (licences are issued by the administrative body of the county in charge of
transport). Counties may alternatively decide that public passenger transport services in
their respective area are carried out on the basis of concessions issued for a period up to
7 years, pursuant to the Law on Concession (Law No. 143/2012).
Special regular coach services which are fully liberalised.
Occasional coach services which are fully liberalised.
National taxi and shuttle services.
International coach services which are regulated under EU Regulation 1073/2009 (or in
cases of non-EU countries under bilateral agreements).
Market access
Access to the domestic market for regular services
B.169 Licences to operate county and inter-county transport services are issued at the request of
carriers, compliant to a number of requirements:
harmonised timetable;
proof of transport capacity;
description of the timetable;
a written agreement on the joint delivery of transport services, if transport is delivered by
two or more carriers.
B.170 If a county decides that public transport services are to be carried out on the basis of a
concession, concessions are tendered pursuant to Law No. 143/2012 (Law on Concessions).
Data
Table B.19: Croatia: inter-county road transport of passengers (2010-2014)
Table B.21: Croatia: county road transport of passengers (urban and suburban bus transport) (2010-2014)
Passengers
Passengers
Kilometres
Kilometres
Kilometres
travelled
travelled
travelled
Number
Number
Number
carried
carried
2010 1,647 93,604 373,239 407 16,849 183,119 1,240 76,755 carried
190,120
2011 1,590 86,805 364,382 394 16,150 173,177 1,196 70,655 191,205
2012 1,579 84,807 363,198 383 14,903 174,139 1,196 69,904 189,059
2013 1,571 83,139 371,840 369 14,586 177,596 1,202 68,553 194,244
2014 1,549 83,860 388,295 369 15,693 191,899 1,180 68,267 196,396
Table B.22: Croatia: employment in urban and suburban bus transport (2010-2014)
Hungary
Overview
B.181 The domestic market for coach services is not yet liberalised in Hungary. Regular bus and
coach services are subject to Public Service Obligations (PSOs) and thus provided under a
concession framework. Non-PSO services such special regular services provided by large coach
operators, or occasional tourist services, are provided on a commercial basis.
B.182 The majority of regular services are provided by incumbent regional road passenger transport
companies which occasionally subcontract to smaller operators. There are only three non-
incumbent operators serving domestic PSO routes. The current concession framework was
extended in 2009 up to 2017 for those operators to which PSOs were awarded. A new
concession framework is currently being prepared by the Ministry for National Development
(NFM) and new operators are expected to enter the market from January 2017.
B.183 Almost all Hungarian settlements can be reached by bus or coach. However, in Eastern
Hungary the railways have a greater network density and rail is favoured over coach. In most
cases, buses provide a useful, if limited, feeder service.
Regulation and market for coach services
B.184 PSO services are defined and classified on the basis of the Act XLI of 2012 on Passenger
Transport (which is compatible with the EU legislation). Bus and coach services are classified as
follows:
Urban services are the responsibility of the Municipal authorities.
Suburban services, operating up to 70 kilometres from Budapest or any of the 23 towns
with county rights (hat is county seats and cities with more than 50,000 inhabitants) are
the responsibility of the NFM.
Regional services, running within one county (NUTS3) or, in case of services crossing more
than one county, not exceeding 100 kilometres from the origin, are the responsibility of
the NFM.
Long-distance domestic services, exceeding 100 kilometres, are the responsibility of the
NFM.
B.185 The Ministry for National Development (NFM) is the competent authority for all international
passenger transport services.
Market access
B.186 Requests for opening new international coach service are subject to the delivery of the
following official documents to the Transport Authority (NKH):
Timetable with the exact locations of stops and exact border stations;
Driving plan for the drivers based on AETR agreements;
Tariff system for all routes;
Route map;
Copy of Community licence; and
Agreement for the use of the stop by the owner of the location, such as at petrol stations.
B.187 Services to countries outside the EU are subject to bilateral agreements. The license is
released for each vehicle and costs 13,690 HUF (approximately €45) per year. The permission
is issued by NKH or, in the case of foreign applicants, the applicant’s transport authority issues
the license following approval by NKH.
Employment
B.188 Roughly 17,000 people are employed in domestic regional and long-distance bus and coach
transport. The number of employees has remained relatively stable over recent years. No
substantial changes in working conditions have been acknowledged due to Regulation
1073/2009. However, there is a growing shortage of labour, particularly with respect to
drivers.
Enforcement
B.189 The “Passenger Rights and Market Control Division” under the National Transport Authority
(NKH) is in charge of enforcement of all regulations for bus and coach transport.
Competition and discriminatory practices
B.190 The main issues processed in 2014 by the “Passenger Rights and Market Control Division” fell
under these categories:
Cancelled scheduled services (16);
Ticket refund claims (11);
No customer service answer from service provider (9);
Delays (2);
Unfair customer policy (2); and
Failure of assistance provision (1).
B.191 In most cases multiple reasons for raising a complaint were mentioned. From a total of 23
complaints, 16 were upheld and sanctions between HUF 100,000 (about €320) and HUF
1,000,000 (about €3,200) were imposed to the service providers. In two cases an examination
at the international level took place with the involvement of the respective foreign transport
authority.
Infrastructure issues
B.192 There are 115 coach terminals in Hungary. The local operators or the Public Administration
(the Municipal Authorities or the State) own the terminals. The terminal quality varies, but
there is trend towards quality improvements.
B.193 With respect to the definition of coach stops, the only requirements for their definition relate
to:
The certification of safety conditions for passengers;
The agreement of the area’s owner to its usage as a coach stop; and that
The stop should be clearly marked onsite and on the website of the service provider.
Passengers with reduced mobility
B.194 In 2011 there were about 577,000 people with reduced mobility in Hungary.
B.195 The Passenger Rights and Market Control Division under NKH is in charge of monitoring the
compliance of coach services with PRM rights. Only a small number of international/long-
distance buses (ca. 3%) are currently accessible to wheelchairs. On the contrary, suburban
services in Budapest are mostly served by low-floor buses.
Domestic
International
Occasional
Information Unit Year
Regular
regular
Special
Total
Number of domestic
Number 2015 10 50 100 160 10
operators
Number of
Number 2015 1 4 5 15
international operators
Number 2014 18,000 1,500
Number of employees
Change from 2009 -8% 15%
Number of drivers Number 2014 10,000 1,200
Vehicle-kilometres Thousand 2014 365,000 50,000
Number of passengers Thousand 2014 450,000 300
Passenger-kilometres Million 2014 8,500
Revenues Million (€ or local) 2014 285
Turnover Million (€ or local) 2014 435
Ireland
Overview
B.197 Ireland has only one land border, with Northern Ireland, part of the UK, and international
travel by all modes is dominated by travel to and from the UK.
B.198 The major cities are connected to Dublin with good roads but relatively slow and infrequent
rail services, allowing coach to compete effectively with rail for many interurban journeys. This
means that, unlike in some other Member States, coach travel in Ireland does not have the
characteristics of an inferior good.
B.199 Córas Iompair Éireann (CIÉ) is the public body responsible for the provision of most public
transport services in Ireland. Services are delivered through three subsidiary operating
companies: bus services by Dublin Bus and Bus Éireann and rail services by Iarnród Éireann.
B.200 Bus and coach services are delivered by two means:
Licensed services, which are fully liberalised and are predominantly tourist services and
long-distance interurban services.
Public Service Obligations (PSO) services which are regulated, contractually specified and
are predominantly local rural, local urban and commuter services.
B.201 In 2013 there were 80.2 million scheduled vehicle-kilometres on licenced services, which
represented nearly 50% of the total.
Regulation and the market for coach services
Regulation
B.202 Commercial bus and coach licences are awarded by the National Transport Authority (NTA), a
statutory body of the Department of Transport, Tourism and Sport (DTTAS). Services requiring
them are defined in the Public Transport Regulation Act 2009 as where:
each journey is open to use by any member of the public;
a charge or charges are paid in respect of each passenger; and
except where the NTA otherwise determines, the service is provided on a regular and
scheduled basis and carriage is provided between specified terminal points or along a
specified route or otherwise in accordance with a published timetable.
B.203 Services that are exempt from the need for a licence include PSO services, school buses,
private hire services and international services authorised under EU regulation 1073/2009.
The market for coach services
B.204 Bus Éireann, established in 1987 as a subdivision of CIÉ, provides most of the bus and coach
services in Ireland. The three main services it operates are Expressway, school transport and
PSO services. It also offers day tours, private hire and commuter services in major cities.
B.205 Expressway is not subsidised and operates domestic interurban coach services on over 30
routes that link that majority of major towns and cities in Ireland. More than half of scheduled
routes are to and from Dublin and tend also to be the busiest routes. In 2013 Expressway
services carried a total 6.8 million passengers in a fleet of 181 vehicles.
B.206 Bus Éireann operates international services to the UK and the rest of Europe under the
Eurolines brand, and some services to Northern Ireland are operated jointly with Ulsterbus.
B.207 Many other private operators also operate licenced commercial routes, tours and private hire
operations. Examples include Aircoach, JJ Kavanagh and Sons and Matthews Coaches.
B.208 The NTA states that in 2013 there were 124 commercial operators with active licences and
20.09 million journeys on licensed services, representing about 12% of total bus and coach
services. The NTA does not distinguish between buses and coaches in its statistics, but we
estimate from data on passenger journeys, vehicle-kilometres and fleet size that Bus Éireann’s
Expressway service comprises approximately 25% of Ireland’s coach market.
Market access
B.209 The interurban coach market is fully liberalised and licences for domestic regular services are
granted for a period of 3 years. Domestic and international licences are only refused if the new
route is judged to infringe an existing PSO service. In 2013 the NTA:
granted 29 licences for regular international travel, all between the Republic of Ireland
and Northern Ireland;
refused 2 international licences as permitted under Regulation 1073/1009; and
refused 7 domestic licences.
Employment
B.210 In 2013 Bus Éireann had 2486 employees, 216 of whom were employed in Expressway
services. The Coach Tourism & Transport Council of Ireland, an industry association, has over
60 members, which they claim employ approximately 1750 people. This suggests that total
employment in the coach sector is approximately 2,000 people.
Enforcement
B.211 DTTAS is responsible for policy oversight of the sector, including:
The licensing framework for Large Public Service Vehicles, which is administered by the
national police service, An Garda Síochána.
The licensing framework for Road Passenger Transport Operators Licences, which is
administered by the DTTAS’s Road Transport Operator Licensing Division.
The policy framework for the operation of bus services for hire and reward including the
licensing of scheduled services, which is administered by the NTA.
The enforcement of bus and coach passenger rights is the responsibility of the NTA.
Competition and discriminatory practices
B.212 PSO services have in the past been specified in Service Level Agreements (SLAs) between the
Department of Transport and the operators, Dublin Bus and Bus Éireann, who are both
subsidiary companies of CIE. In 2009 the NTA established legislation that replaced these SLAs,
on a formal contractual basis, with 5-year direct awards from December 2009 to December
2014.
B.213 In 2013 the NTA re-awarded Dublin Bus and Bus Éireann PSO contracts from December 2014
to December 2019. However, it was decided for the first time that 10% of the services in each
contract would be subject to competitive tender to begin operations in 2016. PSO services are
predominantly local and commuter services, and we understand that only a small proportion
are operated by coaches. Licences for commercial routes are only denied if the route is
deemed to infringe on an existing PSO service.
Table B.24: Ireland: licensed and PSO bus services operations (2013)
Source: NTA.
Table B.27: Ireland: completed journey forms for Irish operators (2014)
Luxembourg 32 8,800
Source: NTA.
Note: definition of passengers and passenger-kilometres for international services may not be additive with other
Member States.
Luxembourg
Overview
B.219 We found little information on the coach market in Luxembourg. National statistics do not
distinguish bus and coach or PSO and non-PSO services.
Regulation and the market for coach services
B.220 We found no information specific to the regulation of the domestic coach market.
Market access
B.221 In 2013, 38 companies were registered to provide domestic bus and coach transport.
Employment
B.222 The FLEAA (Fédération Luxembourgeoise des Exploitants d’Autobus et d’Autocars) reports that
2,200 staff are employed by coach and bus operators. No further information appears to be
available from other data sources.
Enforcement
B.223 We found no information specific to enforcement in the coach market.
Competition and discriminatory practices
B.224 We found no information found on competition and discriminatory practices.
Infrastructure and terminals
B.225 We found no information found on infrastructure and terminal issues.
Persons with reduced mobility
B.226 We identified no information on persons with reduced mobility on Luxembourg.
Latvia
Overview
B.227 Two main pieces of legislation regulated the bus and coach market in Latvia:
the Road Transport Law, enacted in 1995 and amended in 2007; and
the Law on Public Transport Services enacted in 2007.
B.228 These pieces of legislation distinguish between regular service, special regular service and
occasional services. All intercity regular services are operated under public service obligations
(PSO) on a concessionary basis. There were 15 coach operators with domestic licences in
Latvia in 2014, compared to 408 operators with international licences.
Regulation and the market for coach services
B.229 The competent authorities for passenger road transport are:
The Ministry of Transport;
The Public Transport Board, which has a role in decision and supervision for public
transport in Latvia;
The Road Transport Administration, which acts on behalf of the state in organising
regional and inter-city routes;
The Municipalities of the nine Republic Cities , which are in charge of organising public
transport services along urban routes.
B.230 Transport of passengers by bus and coach is regulated by two main pieces of national
legislation:
The Road Transport Law, enacted in 1995 and subsequently amended in 2007, which sets
the procedures for obtaining a licence to carry passengers;
The Law on Public Transport Services, enacted in 2007, which regulates the provision of
public transport services.
B.231 In addition, a number of regulations issued by the Cabinet of Ministers of Latvia regulate
specific aspects of the provision of road passenger transport and supplement to the two Laws
referred to above.
B.232 The Road Transport Law distinguishes between regular, occasional and special regular
passenger services. Regular services are provided under a concession regime and are tendered
subject to the Public Procurement Law of 2006), these are subject to PSO Regular public
service operations are organised as follows:
City network services within the territory of one of the nine Republic Cities and the
surrounding area.
Regional local network services within one administrative/planning territory.
Regional inter-city network services crossing more than one administrative/planning
territory.
B.233 From January 2015 regional inter-city and local routes have been managed within a single
regional network under the responsibility of the Road Transport Administration.
B.234 Compensation is paid by the State or Municipality to operators to cover the costs of providing
public transportation services-costs which exceed revenues and profit due to the level of fares
set by the competent authorities. Compensation is also paid to cover the cost of providing fare
discounts to people with disabilities and children under school age.
B.235 In 2014, compensation payments to public bus and coach service providers were as follows:
urban network: € 6.6 million;
regional local network: € 18.6 million; and
regional inter-city network: € 17.6 million.
B.236 For comparison, the regional inter-city rail network subsidy was € 45.2 million.
B.237 Occasional and special regular coach services are not subject to PSO and are regulated within
the framework of the Road Transport Law on the basis of a number of by-laws. The fares for
passenger services not subject to PSO are set on a pure commercial basis.
Regular international coach services, as well as international occasional services, are
organised entirely in compliance with Regulation 1073/2009.
Market access
B.238 All national regular intercity services are operated under PSO and are concessions tendered
subject to the Public Procurement Law of 2006. Non-domestic operators can apply and
procedure does not differ from domestic operators.
B.239 Operators serving the domestic market must hold a licence and a licence card is issued for
each vehicle used. If a Community licence is issued, it can be also used for domestic
operations. Licences and Community licences are issued within 30 days from the date of
submission of the application, while licence cards (the documentation for each vehicle) and
certified true copies of a Community licence are issued within 7 days from the request.
Employment
B.240 Working conditions have improved in Latvia recent years, but taking into account that
Regulation 1073/2009 is just a recast of Regulation 684/92, changes in working conditions
cannot been attributed to of the adoption of this regulation.
Enforcement
B.241 The enforcement authority is the Road Transport Administration which supervises and
monitors the coach market and checks compliance with related regulations, including
Regulation 1073/2009.
Competition and discriminatory practices
B.242 The Latvian Competition Council had carried out an investigation regarding discriminatory
practices at coach terminals at the request of some operators who claimed they were
prevented from operating their services. Other lawsuits due to unfair pricing have been
reported: currently there is one infringement procedure related to coach stations allegedly
practicing unfair pricing toward coach operators.
Infrastructure issues
B.243 There are 35 bus terminals in Latvia, most owned by private operators, including the most
important terminal, in Riga, which is in the city centre and well linked to other transport
modes and hubs, such as Riga International Airport. In some cases coach operators are not
required to use specific terminals, but stopping points must be agreed with the respective
competent authorities, the municipalities.
Persons with reduced mobility
B.244 The Riga terminal is equipped to serve persons with reduced mobility and has been certified
under a quality management system, LVS EN ISO 9001:2009. The terminal staff are trained to
help people navigate the station and to get on and off the coaches. PRMs can easily move with
wheelchair within the terminal, and all equipment and devices (such as fittings in washrooms
and toilets) are at a comfortable height and can be reached from a wheelchair. Riga
International bus terminal marked all doors with yellow slashes, making them more visible and
easier for persons with disabilities to use. Where the coaches stop there are large numbers on
the floor to mark each stop to aid those with impaired vision.
Regulation 1073/2009
B.245 Regulation 1073/2009 is a recast of Regulation 684/92 thus its introduction did not entail
major changes.
Data
Table B.28: Latvia: authorisations and licences of coach services (2009-2014)
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
National passenger carriage 103 82 57 44 32 30 26 22 20 15
International passenger carriage 351 402 452 505 468 453 438 431 425 408
Number of
Length Passenger- Revenues
Route operators on Passengers Fare (€)
(kilometres) kilometres (€ million)
route
Riga-Daugavpils 224 3 259,244 43,133,168 5.93 1,514,577
Riga-Rezekne 257 2 133,044 16,947,227 4.95 504,213
Riga-Jekabpils 140 1 78,796 9,001,693 4.16 326,354
Riga-Ventspils 200 2 327,311 44,196,418 5.07 1,573,355
Riga-Valmiera 114 1 258,688 21,659,091 3.10 802,753
Riga-Liepaja 220 2 501,819 64,995,919 4.79 2,226,592
Riga-Aluksne 224 1 125,320 12,211,266 3.92 455,927
Riga-Bauska 67 3 487,227 24,414,504 2.04 994,966
Malta
Overview
B.246 Malta is a group of islands on which bus travel is the only form of scheduled public transport,
but no two points connected by road are more than 30 kilometres apart.
B.247 The bus and coach sector was largely unregulated until 2011, since when bus and coach
operations have been provided through a public bus network, private hire services and tourist
services.
Regulation and market for coach services
B.248 From the 1970s onwards, public transport services in Malta were provided by privately owned
and operated buses and coaches operating to timetables set by the transport authority.
Routes were allocated by rota, with half the buses operating public routes and the other half
operating private hire or school operations.
B.249 In July 2011 Transport Malta, the competent authority, implemented a major restructuring of
public bus services and appointed Arriva as the sole operator. The reforms sought to improve
levels of service, reduce subsidy and standardise the fleet, routes, and fares.
B.250 Arriva ceased operations in January 2014 due to financial difficulties and was nationalised by
the Maltese government. Since January 2015, services have been operated by Autobuses
Urbanos de León.
B.251 Tourist and private hire services are also provided by private operators. These operations are
fully liberalised, subject to authorisation from Transport Malta.
B.252 The Maltese national statistics office reports that in the fourth quarter of 2013 there were 238
licensed route buses and 344 coach and private hire buses. Transport Malta reports there
were just under 33 million passenger journeys on public buses in 2011.
Market access
B.253 A passenger Transport Vehicle (PTV) licence is required to operate tourist or private services in
Malta. These licences are granted by Transport Malta for a fee, provided that the applicant
holds a Carriage of Passenger Operator Licence and the vehicle complies with the required
specifications and standards.
Employment
B.254 The Maltese national statistics office reports that 3,443 people were employed in the land
transport sector in 2013.
Terminals
B.255 There is no issue of access to bus terminals for long-distance services, which do not exist, but
the existing bus terminals can be constrained and require expansion. In November 2015 the
Malta Public Transport Authority announced that, in association with the introduction of seven
new routes, Valletta bus terminal would be extended from 17 to 29 bus bays.
Persons with reduced mobility
B.256 Malta did not designate any bus terminals under Article 12 of Regulation 181/2011 because
there are no long-distance services. However, we understand that Victoria, Bugibba, Ciekewwa
and Valletta bus terminals are all equipped with disabled parking and are wheelchair
accessible.
B.257 Public buses have low floors and designated seating for PRM, but anecdotal evidence suggest
that private coaches are not always accessible.
Summary of key issues
B.258 Malta has no long-distance or international transport markets and, in consequence, no regular
or special regular coach sector.
Netherlands
Overview
B.259 According to the Passenger Transport Act 2000, road passenger transport services are
classified as public transport (subject to public regulation under a concession regime) or
private transport (run on a purely commercial ground and not regulated by the government).
The market penetration of interurban (long-distance) regular coach services is limited by the
presence of a fast and frequent medium and long-distance rail network, the small surface area
of the country, as well as regulatory and competition issues.
B.260 The number of public transport vehicles in 2014 was about 6,500, while the number of private
transport vehicles was about 4,700. Public transport operators offered about 490 million
vehicle-kilometres in 2014. In the same year, private Dutch transport operators offered 191
million vehicle-kilometres, 107 million of which run in the domestic market and 84 million in
the foreign market. A further 24 million vehicle-kilometres delivered by foreign operators in
the Netherlands are also provided.
History of the bus and coach market
B.261 In 1994, the national bus holding company VSN (United Regional Transport Netherlands)
introduced a national scheme for long-distance buses, called Interliner. These services
operated along provincial roads and had higher vehicle and bus stop specifications which
included higher levels of user comfort on vehicles, real time information and bike parking at
the stops. These services were well integrated with train times and ticketing. Between 1995
and 2000, Interliner was very successful, operating as many as 30 routes in the country and
carrying over 5 million passengers per year.
B.262 The Passenger Transport Act 2000 led to a fundamental reorganisation of the road passenger
transport services and replaced the former authorisation regime with competitive tendering in
all urban and regional transport (the new framework came into full operation in 2008). The
organisation of public transport was shifted from a market-led initiative system (substantially
subsidised by the national government) towards a decentralised regime of public tendering at
the regional level (managed by 19 Public Transport Authorities or PTA).
B.263 Express bus services were thus required to fit within the regional concession areas and the
national brand disappeared (during the decentralisation activities, VSN was split up and
rebranded as Connexxion). To promote competition, parts of the network were required to be
sold off to private operators. Several variants of the Interliner concept (Qliner, Hanzeliner)
emerged after decentralisation, often owned by foreign transport operators including Arriva,
Veolia and Transdev.
B.264 Express bus services are currently known as “Hoogwaardig Openbaar Vervoer” (HOV, high-
quality public transport). HOV-systems include both rail (light-rail and tram) systems and bus
systems that serve longer distances, connecting different urban centres in a region. HOV-bus
services are express services that connect different urban cores, often via highways or
dedicated bus infrastructure, thus increasing the speed of the service. The distance between
stops for these services is larger than for regular bus services.
Regulation and the market for coach services
B.265 The Ministry of Infrastructure and Environment is responsible for the road passenger transport
policy and legislation. The Passenger Transport Act 2000 defines two regimes:
Public passenger road transport, defined as services which do have a timetable (regular
intervals along a specified route) which are operated in a concession regime and are
subject to public service obligations. Concessions are managed by the 19 regional Public
Transport Authorities shown in Figure B.13.
Private passenger road transport, defined as services which do not have a timetable, and
for which the market is free. Private road passenger transport services only need a
certificate by the KIWA Register in order to enter the market.
Figure B.13: Netherlands: Public Transport Authorities (left) and concession areas (right) (1 January 2015)
Legend: Legend:
01: OV Bureau Groningen-Drenthe 1. Vlieland 19. Veluwe
02: Province of Friesland 2. Terschelling 20. South-Holland
03: Province of Overijssel 3. Ameland 21. Province of Utrecht
04: Province of Flevoland 4. North and South West 22. Regio Utrecht
05: Province of Gelderland Friesland and 23. Haaglanden region
06: Province of Noord-Holland Schiermonnikoog 24. Haaglanden city + City
07: City Region Amsterdam 5. Southeast Friesland bus Hague
08: Province of Utrecht 6. GD 25. Rotterdam Rail + Bus
09: Province of Zuid-Holland 7. Noord-Holland Rotterdam
10: Metropolitan Region Rotterdam Den Haag 8. IJsselmond 26. DAV-area
11: Province of Zeeland 9. Middle Overijssel 27. Rear-Rivierenland
12: Province of Noord-Brabant 10. Twente 28. Arnhem-Nijmegen
13: Province of Limburg 11. Haarlem-IJmond 29. Voorne-Putten and
12. Zaanstreek Rozenburg
13. Waterland 30. Hoekschewaard -
14. Urban transport Lelystad Goeree-Overflakkee
15. urban and regional 31. Zealand
Almere 32. West Brabant
16. Amstelland More 33. East Brabant
Countries 34. Eindhoven Regional
17. Urban transport 35. North and Central
Amsterdam Limburg
18. Gooi and Vecht 36. South Limburg
concession areas traversed by the proposed bus service, and who would be responsible for
verifying the new service does not compete with existing public transport services (including
rail, metro and tram). Currently no service operates in the Netherlands under this regulatory
framework. Recently, however, an operator (FlixBus) has commenced procedures to apply for
permission to operate two inter-regional long-distance coach services between Eindhoven-
Groningen and Eindhoven-Enschede. FlixBus has asked the Province of Noord-Brabant (PTA)
for permission to offer services through their concession area, without being tendered. The
province of Noord-Brabant is currently discussing this request with the Dutch Government,
bordering provinces and concession operators.
International regular services
B.271 Coach operators must apply to the Kiwa Register for authorisation to operate coach services
on an international route serving the Netherlands. An authorisation can only be declined when
the main purpose of the new proposed service is not to carry passengers between stops
located in different EU Member States (therefore the proposed services do not fall under
Regulation No. 1073/2009), when the proposed bus routes are not viable, or when other
existing public transport services would be jeopardised by the new proposed service.
Private passenger road transport (occasional services)
B.272 According to the Passenger Transport Act 2000, occasional coach services (private road
passenger transport) as well as international coach transport, is subject to European
legislation. Occasional services are free to operate in the Netherlands subject to compliance to
the EU laws and authorisation by the Kiwa Register. There is no capacity criteria to limit the
supply of occasional coach services and fares are set by operators. International occasional
services (“own-account transport operation”) is also allowed without further restriction under
the EU legislation.
Employment
B.273 There are about 36,600 drivers employed in public transport activities, and about 5,500 drivers
employed in private transport activities.
Enforcement
B.274 Within the Ministry of Infrastructure and Environment, the Human Environment and Transport
Inspectorate carries out enforcement activities. In the field of road transport the Inspectorate
often mandates recognised private institutions (such as classification societies) to issue
permits/certificates subject to the compliance of the applicant operator against a series of
legal requirements. Since 2010, the quality authority Kiwa NV (Kiwa Register) has been
responsible for this task for bus and coach services. Despite this, the Inspectorate maintains a
role of supervision on the work of Kiwa Register and the Inspectorate remains authorised to
withdraw permits and certificates. The majority of rules and obligations for drivers, operators,
personnel, vehicles and passengers is set in EU legislation.
B.275 The National Department for Road Transport is responsible for collection of data on major
infringements and reports to the European Register of Road Transport Undertakings (ERRU),
pursuant to Article 18 of Regulation 1071/2009.
Data
Table B.35: Netherlands: authorisations and journey forms issued by the KIWA Register (2010-2014)
Table B.37: Netherlands: private transport (occasional coach services) (million vehicle-kilometres) (2010-2014)
Portugal
Overview
B.284 Road passenger transport (including both urban and interurban bus and coach transport) in
Portugal accounted for 546,383 journeys in 2013. Passengers were carried on 10,452 vehicles
belonging to a total of 654 bus and coach firms. In 2013 road passenger transport represented
58% of public transport in terms of total passengers carried.
B.285 At the end of September 2015 there were 567 firms authorised with EU Community licenses to
provide national and international passenger transport by road, 56 of which hold concessions
for a total of 519 express services, defined as. routes of more than 50 kilometres between
established terminal points).
B.286 Rede Nacional de Expressos is the main network of operators supplying express services. The
network is based in Lisbon and was founded in 1995 with the primary aims of ensuring long-
distance passenger transport and the delivery of packages between major cities and regions of
Portugal. The network is composed of several coach operators including Transdev Portugal,
Rodoviária do Tejo, Barraqueiro Transportes, Rodoviária da Beira Interior. While Rede
Nacional de Expressos does not own any coaches (the fleet belongs to the company's
shareholders), most of buses associated to the network use the Rede Expressos brand livery.
Currently the network employs 39 workers, manage a total fleet of 200 vehicles, and represent
about 70% of the overall market for express services in terms of passenger carried.
Regulation and market for coach services
B.287 The Lei de Bases do Sistema de Transportes Terrestres no. 10/90 (LBSTT) is the primary
legislation governing the provision of passenger transport in Portugal. Regulamento de
Transportes em Automóveis (Decreto-Lei no. 37 272, 31/12/1948) regulates road transport
operators.
B.288 The Portuguese National Public Transport Agency (IMTT, Instituto da Mobilidade e dos
Transportes Terrestes) is responsible for the issue of road transport licenses.
B.289 Road passenger transport services are classified as follows:
Urban, suburban and regional transport is within the competencies of the Municipalities
and are subject to a concession regime.
Interurban Public Transport is within the competencies of the IMTT and is liberalised.
B.290 Within interurban public transport, Express and High Quality Services are those qualified by
the IMTT in terms of minimum route length (50 kilometres) and other criteria such as the
maximum number of bus stops and vehicle type. The choice of the route in the case of Express
and High Quality Services is less restricted than in the case of urban routes.
Market access
B.291 Access to the market for road transport is subject to the following requirements: an EU
license, relevant professional capacity documentation, company financial statements and
having a national authorisation. Access to the market for domestic inter-regional regular
services is subject to a request to the IMT. The carrier must definite the proposed services in
terms of route, stops, and timetable. The only procedures and authorisations needed to access
the international market for regular services are to hold the required community license
issued by the IMT. Regular international services are authorised for up to 5 years.
B.292 Special regular services do not need authorisation if they are covered by a contract established
between the organiser and the carrier. A similar regime applies to occasional coach services.
Employment
B.293 We found no information on employment data in the coach sector in Portugal.
Enforcement
B.294 We found no evidence of enforcement problems in the coach sector in Portugal.
Competition and discriminatory practices
B.295 We found no evidence of discriminatory practices in the coach sector in Portugal.
Infrastructure issues
B.296 Most coach terminals in Portugal are publicly owned (84% of the total), with the remainder in
private ownership.
B.297 Publicly owned terminals often have outdated facilities and equipment. This, in turn, has
spurred an increased supply of private infrastructure, mostly in larger cities. For example,
Rede Nacional de Expressos operates the “Sete Rios” bus and coach terminal in Lisbon.
Market data
Total road transport services
Table B.38: Portugal: transport services by type of service (2011-2014)
Destination
Year Type of service
Spain France Switzerland Germany Luxembourg Other
Total 8,863 5,379 1,311 315 739 547
2014 Regular 4,864 4,879 895 307 733 488
Occasional 3,999 501 416 8 6 59
Total 7,334 5,050 1,274 322 556 476
2013 Regular 4,898 4,268 780 308 501 389
Occasional 2,436 782 493 15 55 87
Total 6,462 4,121 1,571 597 589 386
2012 Regular 3,299 3,305 1,228 554 468 328
Occasional 3,163 816 343 43 121 59
Total 6,072 2,993 2,108 759 737 448
2011 Regular 3,655 2,522 1,745 738 633 399
Occasional 2,418 472 363 21 104 49
Table B.43: Portugal: international passengers by type of service and destination country (thousand)
Destination
Year Type of service
Spain France Switzerland Germany Luxembourg Other
Total 309.2 197 23.3 4.5 15 12
2014 Regular 144.8 177.5 14.5 4.2 14.8 8.8
Occasional 164.3 19.5 8.7 0.4 0.2 3.2
Total 251.1 187.1 35.3 9.8 19.2 15.7
2013 Regular 156.9 158.7 26 9.2 17.1 11.9
Occasional 94.3 28.4 9.3 0.6 2.1 3.7
Total 223.9 156 40.1 15.9 20.9 12.1
2012 Regular 90.6 123.6 33.3 13.6 18.5 8.7
Occasional 133.3 32.4 6.8 2.3 2.3 3.4
Total 241.7 123.7 70.1 31.2 28.7 14.4
2011 Regular 112.3 95.8 62.9 21.6 25.8 12.5
Occasional 129.4 27.9 7.2 9.7 2.9 1.9
Table B.44: Portugal: international seat-kilometres by type of service and destination country (million)
Destination
Year Type of service
Spain France Switzerland Germany Luxembourg Other
Total 239.2 399 89.2 15.5 50 28
2014 Regular 89 348.9 63.3 13.9 49.3 18.7
Occasional 150.2 50.4 25.8 1.6 0.6 9.5
Total 264.5 585.9 214 81.8 85.2 66.9
2013 Regular 136.4 526.5 167 79.5 79.8 54
Occasional 128 59.5 47.5 2.3 5.4 13
Total 233 339 142.2 73.8 63.1 31.7
2012 Regular 72.4 294 124 68.7 52.3 21.9
Occasional 160.6 44.8 18.3 5.1 10.7 9.8
Total 251.6 276.6 196.1 95.2 57.1 37
2011 Regular 89 234.2 172.3 92.1 49.3 28.9
Occasional 162.7 42.5 23.8 3.1 7.8 8.1
Table B.45: Portugal: international passenger-kilometres by type of service and destination country (million)
Destination
Year Type of service
Spain France Switzerland Germany Luxembourg Other
Total 147.4 338 57 14.2 36 20
2014 Regular 45.2 302.2 46.5 13.3 35.4 11.9
Occasional 102.2 36.1 10.5 0.9 0.5 8.4
Total 163.4 326.8 59.9 23.8 38.4 10.8
2013 Regular 79.7 283.4 44 22 34.1 4.7
Occasional 83.6 43.4 15.9 1.8 4.3 6
Total 139.3 258 75.8 38.7 38.5 23
2012 Regular 51.4 216.4 65.1 33.5 34.4 16.7
Occasional 87.9 42.1 10.7 5.2 4.1 6.3
Total 145.6 187.2 130.7 56.9 49.8 26.5
2011 Regular 67.1 154.7 125.6 56.1 45 23.4
Occasional 78.5 32.5 5.2 0.8 4.9 3.1
Slovenia
Overview
B.298 The Road Transport Act (ZPCP-2) 2006 regulates passenger transport in Slovenia. Regular
public passenger transport in Slovenia has been provided as a public service since 2004 with
concessions granted directly (without public tender) to those operators which were operating
regular public transport over specified routes in 2003-2004. Currently there are 35 concession
operators in Slovenia. The current concessions will expire at the end of 2015. International
coach transport is fully liberalised in line with Regulation 1073/2009.
Regulation and the market for coach services
B.299 Public passenger road services operating in Slovenia are classified as:
Urban public services, which can be subject to PSO (this is mandatory in cities with a
population greater than 100,000) and subsidised by the municipality budget (pursuant to
the provisions of Article 53 of the Road Transport Act).
Regular regional/national coach services (defined as all public transport road services
other than public road transport in urban traffic), which are subject to PSO (and
subsidised by the State budget) and run under a concession regime (pursuant to the
provisions of Article 50 of the Road Transport Act).
National special regular coach services, which are fully liberalised.
National occasional coach services, which are fully liberalised.
Taxi and shuttle services.
International services, which are regulated under EU Regulation 1073/2009.
Market access
B.300 The access to the international coach market is fully liberalised, while national regular services
are regulated under a concession regime and are subject to PSO.
Access to the domestic market for regular coach services
B.301 Following the expiry of the current concessions regular passenger transport will be operated
under public service obligations following a public tendering exercise. The Ministry of
Infrastructure awards concessions to the best-value-for-money operators. The Ministry of
Infrastructure determines concession routes, the type and scope of services, standards of
accessibility, fares and the quality of services provided.
Access to the international market for regular services
B.302 International carriage of passengers can be carried out subject to possession of a Community
Licence. The authorisation procedure is set by Regulation 1073/2009. Some conflicts have
occurred within the authorisation process when operators have tried to provide services on
routes already served by PSO services.
Access the coach market for other services (occasional services)
B.303 Operators have to obtain a road transport licence from the Ministry to operate occasional
transport services. The market for occasional services is fully liberalised.
Employment
B.304 Employment in the coach industry in Slovenia is not reported. Stakeholders indicated no major
changes in working conditions since the entry into force of Regulation 1073/2009.
Enforcement
B.305 We were informed that an operator with a record of serious and repeated offences might find
it difficult to obtain or renew an authorisation for domestic or international coach services.
Competition and discriminatory practices
B.306 We saw evidence of cases where operators of special regular transport services tried to offer
services on the routes and within the timetables of concession operators. In one case this led
to the introduction of a legal proceeding, which has not yet concluded.
Infrastructure issues
B.307 Coach terminals in Slovenia are owned by local authorities or privately. Non-domestic
operators must pay to access the terminals. Approximately two-thirds of bus stops in Slovenia
are not properly equipped or suitable as an interchange point. In some urban areas regional
buses are not allowed to stop at local city bus stops.
Persons with reduced mobility
B.308 The provision of facilities for PRM in Slovenia is relatively poorly organised and accessibility to
buses is often a problem for PRM. As a result there is limited demand for coach services from
persons with reduced mobility who are often forced to use alternative modes of transport.
Data
Table B.46: Slovenia: interurban public scheduled transport (2010-2014)
Slovak Republic
Overview
B.309 The coach market in the Slovak Republic is subdivided into:
International and interurban services: these are operated by private and semi-private
companies at their own commercial risk.
Regional services: these are subject to PSO and contracted with semi-private operators
(33% of shares in each company are owned by the state). Contracts are awarded by
regional authorities, typically for ten years.
B.310 International services are operated by local (Slovak Lines, Eurobus, SAD companies) and
foreign operators (STUDENT AGENCY, Blaguss, OrangeWays, and by a number of smaller
Ukrainian and Bulgarian operators.
B.311 Long-distance interurban lines are operated by Slovak (TURANCAR, Eurobus, partly-state
owned “SAD” companies) and international companies (RegioJet, Arriva).
B.312 Regional services are contracted to dominant operators by regional authorities with directly-
awarded contracts.
Regulation and the market for coach services
B.313 The transport authorities are defined in the Act No. 56/2012 on road transport. They include:
the Ministry of Transport, Construction and Regional Development;
self-governing regional authorities responsible, with the exception of urban transport, for:
granting and withdrawing transport licenses for regular services and maintaining a
register of activity in the coach market;
imposing penalties for clerical and administrative failures with respect to regular
services within their territory;
approving timetables for regular services;
being the contracting entity within the region, compiling the regional transport
service plan, and providing public funding for PSO services.
district authorities, located in the same cities as regional authorities, responsible for
granting and withdrawing authorisations to road transport operators, as well as granting
and withdrawing Community licenses;
municipalities, for municipal public transport and taxi services.
B.314 Coach services are subject to several regulation regimes according to the following
classification:
Regional coach services within one region are governed under EU Regulation 1370/2007
and domestic Act 56/2012 Coll. Authorisation to operate coach services is provided by the
relevant district authority, the granting of a transport licence (for one or more routes) is
provided by the competent regional transport authority, and public services are
contracted through the regional authorities. These form the majority of subsidised public
passenger road services, although some interurban routes may also be subsidised.
Domestic coach services not subject to PSO (that is, long-distance interurban services) are
governed under the provisions of Act 56/2012 Coll. They are subject to authorisation to
operate coach services by the district authority, with transport licences issued by the
competent regional transport authority. The market is formally liberalised, but
discriminatory practices intended to protect incumbent operators have been reported.
82
Tlačová agentúra Slovenskej republiky (5 January 2015)
Source: Yearbook of Transport, Post and Telecommunication 2014, Strategy of Public and Non-Motorised transport
to 2030.
Note: definition of international passengers may not be additive with other Member States.
Source: Steer Davies Gleave stakeholder consultation, Ministry of Transport, Construction and Regional
Development, Košický samosprávny kraj.
Source: Steer Davies Gleave review of White Paper COM 144 (2011).
C.7 We note that while there is reference to integration between modes, there is no specific
description of what integration would mean for, or within the coach industry. Notably, Annex I
to the White Paper “List of initiatives” begins with “An efficient and integrated mobility
system” but this makes no specific reference to coach.
C.8 We therefore considered a number of possible objectives for market integration as applied to
coach, which we summarise in Table C.2.
Source: Steer Davies Gleave indicative analysis, note that Member States may liberalise further.
C.9 We stress that these objectives are purely indicative, and that we would aim to discuss them
further with the Commission. However, we envisage that a clear list of objectives will be
necessary:
For us to test any proposals we put forward against specific objectives.
For the Commission to have objectives for any proposed intervention, if needed as part of
a future Impact Assessment.
C.10 We also note that “integration” and “liberalisation”, while both potentially positive objectives,
may prove to be incompatible in a number of ways, such as:
Are modes required or permitted to collaborate (“integrated”) or compete (“liberalised”)?
Are fares required or permitted to be inter-available (“integrated”) or not (“liberalised”)?
C.11 In previous studies, including our work on the Fourth Railway Package, we identified potential
tensions between these two objectives, in particular that it is difficult to legislate to require
both integrated ticketing and price competition.
The scope of services to be liberalised
C.12 We noted in our Interim Report how Regulation 1073/2009 subdivides coach services
between:
International and domestic services
Special regular, regular and occasional services
This implies that, potentially at least, there are a wide range of approaches to liberalisation, as
summarised in Table C.3 below.
C.19 Where new services affect existing services, particularly those provided under a Public Service
Contract (PSC), Member States and competent authorities are likely to be concerned if the
second effect (“abstraction”) is large compared with the first one (“generation”).
C.20 European legislation for other transport modes has therefore typically permitted Member
States to take measures to protect PSCs from competition, setting out broad principles and
allowing Member States to provide details of local implementation. One consultee endorsed
this approach, arguing that “the Commission should set a positive vision rather than legislating
on the details”. As we discuss below, however, the coach industry may need to be considered
in greater detail than other modes, for a number of reasons:
The short periods required to plan and introduce (or withdraw) coach services, at least
compared with rail, requiring that procedures to permit or refuse entry are not unduly
slow
The low value of an individual coach service, at least compare with rail or air services,
requiring that procedures to permit or refuse entry are not unduly costly
The wide range of existing domestic regulatory regimes for coach services, and the
different definitions and approaches within them
The measures already permitted to protect PSCs from new services by other modes, and
the potential benefits of adoption of an approach to protection which is consistent
between the modes of services being proposed (entrants) and the modes of services
being protected (incumbents)
C.21 We set out below our initial thinking related to a number of issues, including:
Should protection be defined with reference to:
The service being protected, so existing operators know whether they are protected?
The service being proposed, so new entrants know whether they may enter?
Can or should protection be simplified by use of:
A default assumption on whether entry is permitted?
A simple test of whether entry is permitted?
A burden of proof on one party or another in the event of challenge?
Is harmonisation of protection between modes likely to be:
Essential, to make arrangements acceptable?
Desirable, to make arrangements consistent?
Given all the above, what level of protection would be effective and proportionate?
C.22 We also note that, in a totally deregulated market, with no requirement for operators to give
notice of proposed changes, the market can change in days, with two potential effects:
Passengers have no warning of changes in services on which they have come to rely,
particularly for journey purposes such as commuting.
Competent authorities have no time in which to review whether replacement services are
socially necessary and to design and procure them.
Existing rights to protect PSO services
C.23 Regulation 1370/2007 permits competent authorities, as part of Public Service Contracts
(PSCs), to grant exclusive rights, subject to the constraint in Article 3 that:
“Where a competent authority decides to grant the operator of its choice an exclusive right
and/or compensation, of whatever nature, in return for the discharge of public service
obligations, it shall do so within the framework of a public service contract.”
C.24 Exclusive rights may be awarded to protect PSO services by bus, light rail and rail from services
by any mode of transport, implicitly including coach. Any liberalisation of domestic coach
travel will therefore imply a reduction in the scope for competent authorities to grant
exclusive rights. In principle, this could be achieved by stating that coaches could not be
excluded from certain markets, but in practice a more complex approach might be needed.
C.25 Before considering this further, we examine whether liberalised coach services would in
practice have a material effect on existing PSO services.
The need to protect PSO services
C.26 We summarise below the evidence that liberalised coach services appear most likely to affect
PSO rail services on the grounds that:
Coaches can be operated at fares around half those typical of rail services
Coach operators have developed networks which parallel the interurban rail corridors
Coach may take a large share of the “coach plus rail” medium and long-distance markets
C.27 We discuss in turn examples from:
our 2009 study for the Commission;
the United Kingdom, liberalised from 1980;
Sweden, liberalised from 1988;
Germany, liberalised from 2013 ; and
France, which began to liberalise in mid-2015.
C.28 Our 2009 study found that, where coach services do operate, their fares were approximately
half those charged by the national rail operator83.
C.29 The United Kingdom’s coach industry turnover was estimated in our 2009 study to be around
€1.8 billion84 with a total of 24,326 million passenger-kilometres85, giving an average yield of
€0.074 per passenger-kilometre in 2008. The Office of Rail Regulation reported that average
2010-2011 rail fare box income was 12.1 pence, equivalent to €0.145 per passenger-kilometre
travelled.86 This suggests that in the UK, on average, coach fares are approximately half rail
fares.
C.30 Sweden’s coach market, liberalised in 1988, was estimated in our 2009 study as 920 million
passenger-kilometres, and our 2011/12 study for the European Commission of the Fourth
Railway Package estimated the size of the size of the medium and long-distance rail markets in
Sweden as 7.9 billion passenger-kilometres. Taken together, these data suggest that coach
may have 10% share of the “rail plus coach” market for medium and long-distance journeys.
C.31 The size of the coach market in the United Kingdom was estimated in our 2009 study as 24
billion passenger-kilometres, and our 2011/12 study for the European Commission of the
Fourth Railway Package estimated the size of the size of the medium and long-distance rail
83
“Study of passenger transport by coach”, 4.75
84
“Study of passenger transport by coach”, Figure 4.15
85
“Study of passenger transport by coach”, Table 1.1
86
“GB rail industry financial information 2010-11”, Office of Rail Regulation (now Office of Rail and
Road), 1.17, 12.1 pence at a September 20101 exchange rate of £1 = €1.2
markets in Great Britain as 37 billion passenger-kilometres. Taken together, these data suggest
that coach may have 40% share of the “rail plus coach” market for medium and long-distance
journeys, although a more realistic estimate (see A.384) may be around 20-25%.
C.32 However, so long after liberalisation in Sweden and the United Kingdom it is no longer
meaningful to ask passengers what they would have done in the absence of coach services,
and we did not identify any estimates of the proportion of coach users who would have used
rail or PSO bus services in the absence of their coach service.
C.33 Germany’s liberalisation from 1 January 2013 is comparatively recent, and while the market
may not yet have matured, it is possible to identify some insights into the source of new coach
passengers (as shown in Figure A.3 in Appendix A). Figure C.1 illustrates the extent to which
the principal lines of one of the main operators, ADAC Postbus, use the Autobahn network to
provide relatively high speed connections between cities and conurbations.
Figure C.1: German coach and motorway (Autobahn) networks
87
Source: ADAC Postbus. KCW have produced a similar diagram showing how coaches use the Autobahn network .
C.34 The Bundesamt für Güterverkehr (BAG) has carried out a detailed study of the impact of new
coach services88 and made a number of findings, in particular that:
Coach fares can be less than half rail fares: on the Hamburg to Berlin route, rail fares
ranged from €47.90-78.00, and coach fares ranged from €8.00-30.00
87
“New Long-distance Coach Stations and Licensing Practices, Opportunities for Municipalities”, KCW
88
“Marktanalyse des Fernbuslinienverkehrs 2014”, December 2014
89
Autorité de la Concurrence, Press release 13 November 2013: “Sector inquiry – Regular interregional
coach transport services”
90
Autorité de la Concurrence, Avis n° 14-A-05 du 27 février 2014 relatif au fonctionnement
concurrentiel du marché du transport interrégional régulier par autocar “S’agissant du coût moyen du
transport longue distance par autocar en France, il est estimé par les opérateurs à environ 2,20 euros
par kilomètre, ce qui rend ce mode de transport plus compétitif que le train.
operators to cut costs, particularly on PSO services, although it may be possible to defer new
or replacement investment.
C.41 As we set out above, however, coach services which attract some passengers from rail will
normally also attract some new passengers who would not previously have travelled.
However, there is a prima facie argument that coach services may affect the financial
performance of PSO rail services, and that Member States and competent authorities may
reasonably expect provisions which enable them to protect these services where it is
necessary to do so.
Alternative ways to protect PSO services
C.42 We noted above that Regulation 1370/2007 permits competent authorities to grant exclusive
rights to protect PSO services, and that new entry would not be possible where exclusive
rights have been granted under that Regulation. However, a wide range of different
approaches to protecting PSO services have been proposed or taken, and in many cases the
approach is not to award an exclusive right to an incumbent but to restrict the rights of a
potential entrant. We discuss briefly below restrictions which may be applied to:
new international coach services, provided in Regulation 1073/2009;
new international rail services, provided in Directive 2012/34;
new domestic rail services, applied in Great Britain;
new domestic coach services, formerly applied in Great Britain; or
new domestic coach services, applied in Germany.
Restrictions on the basis of “a detailed analysis”
C.43 Regulation 1073/2009 Article 8 (4) provides that:
“Authorisation shall be granted unless [] a Member State decides on the basis of a detailed
analysis that the service concerned would seriously affect the viability of a comparable service
covered by one or more public service contracts conforming to Community law on the direct
sections concerned. In such a case, the Member State shall set up criteria, on a non-
discriminatory basis, for determining whether the service applied for would seriously affect the
viability of the abovementioned comparable service and shall communicate them to the
Commission, upon its request.”
C.44 The wording of Article 8 (4) cumulatively sets a number of specific tests which must be met,
which we summarise in Table C.4.
Wording Implication
Detailed analysis The analysis cannot be based on a simple rule such as distance,
service frequency, capacity or price.
Seriously affect The effect must be “serious” rather than minor or trivial.
Viability The service must affect “viability”, rather than (for example)
“profitability” or “subsidy requirement”.
Comparable service The services must be “comparable”: it is not clear what makes any
two services “comparable”.
Covered by one or more public service The service must be covered by a PSC: there is no protection to
contracts conforming to Community law “commercial” or open access operations, however marginal their
viability.
On the direct sections concerned The service must operate on the same “direct sections”, which might
mean between the same two bus stations or stops, but could be
interpreted differently.
Criteria, on a non-discriminatory basis The analysis may be detailed, but the conclusions must be based on
predetermined and non-discriminatory criteria, apparently limiting
the scope for each application to be considered on its merits.
C.45 More importantly, while we did not identify whether any interpretations, clarifications or
guidelines of this test have been developed or publicised, we note that “detailed analysis” may
be time-consuming and result in delay. This may be acceptable for the relatively small volume
of international coach services which are the subject of Regulation 1073/2009, but not for the
much larger volume of domestic coach services which might emerge with further
liberalisation.
Restrictions on the basis of an “economic equilibrium” test
C.46 The “Railway recast” Directive 2012/34 Article 11 (1) states that:
“Member States may limit the right of access [] on services between a place of departure and a
destination which are covered by one or more public service contracts which are in accordance
with Union law. Such limitation shall not have the effect of restricting the right to pick up
passengers at any station located along the route of an international service and to set them
down at another, including stations located in the same Member State, except where the
exercise of that right would compromise the economic equilibrium of a public service contract.”
C.47 Note that Member States are not obliged to limit the right of access and may liberalise access
completely if they wish to do so.
C.48 A number of Member States have defined criteria for applying the Economic Equilibrium
test91, but we did not collect or compare approaches on a systematic basis.
91
See Greek Regulatory Authority for Railways (Ρυθμιστική Αρχή Σιδηροδρόμων (ΡΑΣ)),
http://www.ras-
el.gr/uploads/file/RAS%20compromise%20of%20EE%20procedure%20draft%20final_eng.pdf
92
“Criteria and procedures for the approval of track access contracts”, Office of Rail Regulation,
December 2011, 4.43
Restrictions by distance
C.54 Great Britain’s Transport Act 1980 deregulated long-distance coach services only for “Express”
services on which, for each passenger:
“the place where he is set down is 30 miles or more, measured in a straight line, from the place
where he was taken up, or [] some point on the route between those places is 30 miles or more,
measured in a straight line, from either of those places”
C.55 The Transport Act 1985 reduced the critical distance from 30 miles to 15 miles.
C.56 Both Acts provide a clear example of how legislation can be drafted so that a potential
operator can identify whether a proposed new service would be permitted or not, purely by
reference to the intended stopping pattern.
C.57 The combined effect of ORR’s NPA test and the complete liberalisation of coach markets is
that ORR can protect rail operators from new rail services but neither it nor any other body
can protect rail services from new coach services. The range of protection offered in Great
Britain outside London is summarised in Table C.5.
Table C.5: Protection of services in Great Britain outside London
Source: UK legislation, Steer Davies Gleave analysis. Note that no exclusive rights are awarded to any PSO operator.
C.58 In summary, rather than granting exclusive rights to PSO services of any mode (the first two
columns of the table, as permitted in Regulation 1370/2007), Great Britain’ system will only
protect PSO or non-PSO rail services from excessive abstraction by other PSO or non-PSO rail
services. This raises the issue of whether greater symmetry is desirable or necessary in the
treatment of different modes.
Restrictions by distance and time
C.59 Germany’s Personenbeförderungsgesetz (PBefG), which governs the liberalisation of services
in 2013, protects PSOs by means of two tests:
“The entire trip length [is less than] 50 kilometres or the total travel time does not exceed one
hour”93.
C.60 There is further clarification that:
“Carriage of passengers between two stops is not permitted if
93
“Die gesamte Reiseweite 50 Kilometer oder die gesamte Reisezeit eine Stunde nicht übersteigt”,
Personenbeförderungsgesetz § 8 (1)
94
“Die Beförderung von Personen zwischen zwei Haltestellen ist unzulässig, wenn 1. der Abstand
zwischen diesen Haltestellen nicht mehr als 50 km beträgt oder 2. zwischen diesen Haltestellen
Schienenpersonennahverkehr mit einer Reisezeit bis zu einer Stunde betrieben wird. In der
Genehmigung sind auf Antrag für einzelne Teilstrecken Ausnahmen zu gewähren, wenn 1. kein
ausreichendes Nahverkehrsangebot besteht oder 2. das Fahrgastpotenzial der vorhandenen
Verkehrsangebote nur unerheblich beeinträchtigt wird”, Personenbeförderungsgesetz § 42a.
95
“New Long-distance Coach Stations and Licensing Practices, Opportunities for Municipalities”, KCW.
Source: Steer Davies Gleave analysis, other approaches may also be applied.
C.65 Comparison of these approaches reveals a number of features, which we discuss in turn
below.
The mode being introduced
C.66 First, the approaches are applied to a range of different new services: international coach,
international rail, or any rail or coach service. Careful consideration would need to be given to
which, if any, of the existing approaches would be most appropriate for Union-wide further
liberalisation of international and/or domestic coach markets.
The mode being protected
C.67 Second, the approaches differ in the modes they are intended to protect. Regulation
1073/2009 and Directive 2012/34 refer to a “PSC” without specifying a mode.
C.68 As noted previously, we assumed that this means that restrictions may be introduced only to
protect PSC services, but that those PSC services may be operated by any mode. In contrast,
the Office of Road and Rail’s test relates, inter alia, to
“A new service, which might be open access or franchised, which would compete with an
existing open access service and which, if it caused the existing open access operator to
withdraw from the market, could reduce overall competition on the network.”
C.69 This focus on whether a new service would affect an existing one sufficiently to reduce
competition does not limit the protection to PSC services, and in particular allows ORR to
choose to give elements of protection or exclusivity to a commercial or open access rail
services. However, it offers no protection to any bus or coach service, whether provided under
a PSC or not, in their liberalised markets.
C.81 As yet there is no specification, at European level, that an independent body must be involved
in decisions on whether to permit services. Regulation 1073/2009 sets out in Articles 7 and 8
an authorising procedure for international services, which we summarise in Table C.8.
Table C.8: Regulation 1073/2009 authorising procedure and timescales
C.82 The maximum delay which might arise under this procedure is 9 months, comprising:
2 months until a competent authority in another Member State makes a negative decision
2 months until the authorising authority refers to the Commission
4 months until the Commission makes a decision
30 days, effectively a month, until the Commission decision comes into effect
C.83 While this procedure for international coach service is the obvious precedent for domestic
coach services, we envisage that this approach might not be acceptable on grounds of
timescale, cost and the potential high volume of work if processes involve an authorising
authority, other competent authorities, and the Commission. While Member States might be
given the freedom to apply simplified or accelerated processes, for liberalisation to be
effective it might be necessary for the Commission to mandate a simple and rapid procedure.
C.84 One possible approach to devising rules for setting restrictions would be to consult the
industry on an acceptable delay and cost for confirmation that a service could be operated,
and then designing a process, or decision criteria, which could reliably be implemented within
these constraints.
C.85 We also note that, in some Member States, it is relatively common for decisions to be referred
for judicial review, even where few or no decisions have been overturned and the dominant
effect is merely to delay entry. It would also be desirable for the process to be sufficiently
robust and transparent that it would rarely be seen as worthwhile to request judicial review.
Other approaches to setting restrictions
C.86 We also note that other approaches to setting restrictions might be possible. One would be to
require that any new coach service charged a fare of at least (for example) €10, which would
restrict its ability to undercut the price of short distance PSO services. However, this would not
at first sight be consistent with the philosophy in Regulation 1073/2009 Article 8 (4) of placing
no restrictions on fares:
“The fact that a carrier offers lower prices than those offered by other road carriers or the fact
that the link in question is already operated by other road carriers shall not in itself constitute
justification for rejecting the application.”
C.87 There might also be practical issues of enforcing a minimum fare, such as defining what fare
had been charged when an operator offered season tickets for the service.
C.88 Taken together, these points suggest that decisions may be needed on:
What minimum liberalisation the Commission should specify
What maximum restrictions Member States should be permitted to make
Whether these restrictions should apply to new services of all modes
Whether these restrictions should allow protection to PSOs of all modes
Whether these restrictions should allow protection to commercial services of all modes (It
is not allowed in European legislation but appears to be allowed for rail in Great Britain)
Whether Member States, or competent authorities, should be permitted to apply such
restrictions selectively (such as protecting existing rail but not existing coach services, or
protecting open access but not gross cost PSCs, both of which appear to be possible in
Great Britain)
C.89 In addition, the process for making these decisions may need to be rapid, inexpensive and
unlikely to require procedures for appeal, whether to the Commission (as in Regulation
1073/2007) or by a domestic regulatory or other body).
Defining the markets served by pairs of bus stops
C.90 Before considering further the decisions which will be required, and how they might be made
on a cost-effective and timely basis, we discuss briefly the issue of defining what market is
deemed to be served by a particular pair of bus stops, and hence whether:
a rail service would compete with an existing PSO bus service between two bus stop; or
a coach service between two bus stops would compete with an existing PSO rail service.
C.91 A simple and clear approach to defining whether any two transport services (materially)
compete would be a potentially useful approach to developing clear and simple rules relating
to the protection of PSO services. We discuss in turn the issues within rail, air, and bus and
coach services.
Rail
C.92 Rail services can only be provided along railway lines which link clearly-defined stations in a
particular sequence. In most rail networks it is self-evident what services can be operated and
what stopping points, if any, can be included, subject to timetabling constraints. It is relatively
rare for two stations to serve substantially the same origin or destination market although, for
example, high speed rail services to Rome use both Termini and Tiburtina stations. It is even
rarer for two cities to be connected by two railway lines with different stations at each end,
although this is the case between London and Birmingham, with one line from Euston to New
Street, and another from Marylebone to Snow Hill.
C.93 The market for rail travel between most urban areas, therefore, can almost invariably be
defined in terms of trains travelling between the same two main stations along the same line.
Air
C.94 Air services are not constrained to particular en route infrastructure and can, in principle, be
operated between any two airports. Most airports serve distinct markets, although some are
relatively close, with overlapping “catchment areas”, and some cities or regions are served by
a number of airports. Examples include the airports of Dortmund, Düsseldorf, Köln-Bonn and
Mönchengladbach in the Rhine-Ruhr area of Germany or of Västerås, Arlanda and Skavsta
near Stockholm. Uniquely, London is served by six airports at Heathrow, Gatwick, Stansted,
Luton, London City and London Southend. Services from any of these airports compete, at
least to some extent and for some destinations, with services from others.
C.95 The market for air travel, therefore, can almost invariably be defined in terms of aircraft
travelling between the same two airports.
Bus and coach
C.96 Coach services might, in principle, be constrained to operate from a single major coach station
in each urban area, but this is not always the case for a number of reasons:
In some cities a number of coach stations exist, either because it has not been possible to
accommodate all services within a single terminal or because each operator has chosen,
or been expected, to provide their own.
In some cities, multiple terminals are needed to serve the market, providing a range of
starting points.
In some cases, coaches are not constrained by regulation, and have no commercial need,
to serve a particular terminal, and instead serve one or more on-street stops. One
example is airport coaches which provide direct connections to the principal hotels, or
hotel districts, within a city.
C.97 The potential for coach services to serve passengers from a wide range of bus stops
complicates the process of determining whether a proposed coach service linking a defined
series of stops competes, either materially or peripherally, with any other service using nearby
bus stops, coach terminals, light rail stops or railway stations. Specifically it does not appear
practicable to assume that two PSO services, which might be by different modes, do not
compete because they do not serve the same two bus stops.
C.98 This uncertainty may be material to identifying which competent authorities have a legitimate
interest, or grounds to object, to a proposed coach service. In Regulation 1073/2009 Article 8
(1), the authorising procedure requires that:
“Authorisations shall be issued in agreement with the authorities of all the Member States in
whose territories passengers are picked up or set down. The authorising authority shall
forward to such authorities, as well as to the competent authorities of Member States whose
territories are crossed without passengers being picked up or set down, a copy of the
application, together with copies of any other relevant documentation, and its assessment.”
C.99 In other words, Member States must be informed if an authorisation is being considered for a
service which enters their territory, and no matter how briefly or peripherally, even if it does
not stop there.
C.100 This principle may be broadly appropriate to respect the sovereignty of Member States, but
might prove less appropriate if transposed directly to the various regional and local areas
covered by distinct competent authorities in the Member States.
C.101 This analysis also suggests that any test of whether Member States or competent authorities
could apply restrictions might need to serve two distinct purposes:
Identifying whether restrictions could be permitted, noting that such restrictions could
be “automatic”, as in the case of the former “30-mile rule”
Identifying which PSO was affected and hence which competent authorities had a right
to impose, request or waive restrictions
C.102 The former test need not identify, or make reference to, any specific PSO service. However,
the latter test would need to do so, at least for international services or for domestic services
within Member States with more than one competent authority, so as to establish both the
PSO the specific competent authorities which would have a right to be involved in the process.
C.103 In addition, it might also be desirable that such tests could be applied “symmetrically” to
coach and rail modes, so that the test of whether a proposed coach service (PSO or otherwise)
might affect PSO rail was the same as the test of whether a proposed rail service (PSO or
otherwise) might affect PSO bus.
Summary
C.104 Evidence from a number of Member States suggests that coach operators can offer long-
distance services with fares around half those of rail services, that many users of new coach
services may have previously travelled by train, and that liberalisation to permit such services
could have a material effect on viability of some rail services.
C.105 Regulation 1370/2007 gives competent authorities powers to protect PSO services by granting
exclusive rights, but there are a number of alternative approaches based on restricting or
limiting new entry.
C.106 Regulation 1073/2009 sets out an approach to restricting international services, but
compliance with the test is potentially complex and the process of authorising a new service
could take up to nine months. If liberalisation were extended to the much larger domestic
coach markets, it would be desirable for any right to restrict services to be based on a clear,
simple and rapid process.
C.107 Determining whether bus and coach services compete with each other, or with other modes,
cannot be reduced to a simple test of whether they operate between the same bus stops. If
liberalisation is to be supported by a clear, simple and rapid process, this would need to be
based on objective and ideally unambiguous criteria.
C.108 Potentially the simplest test would be to permit any coach service, provided that passengers
were carried at least a minimum distance, such as 50 kilometres, making it clear to potential
entrants what services are and are not permitted. This approach was formerly used in the
United Kingdom and forms part of the current test in France, Germany and Sweden.
C.109 Such a simple test may unintentionally prohibit services which would in practice be no threat
to other PSOs, but any scope for appeal or negotiation raises further issues, such as identifying
the PSO service(s), and hence competent authority(ies) affected, establishing what further
tests should be applied, and the burden of proof, which might lie with the entrant, the
incumbent(s) or be subject to decision or adjudication by an independent body. Any of these
processes is likely add time, cost and the potential for legal challenge, which may be
disproportionate for small services of for small changes to existing services.
C.110 Additionally:
Regulation 1370/2007 permits exclusive rights to protect any PSO
Regulation 1073/2009 requires that international coach services be authorised except on
the basis of detailed analysis of their effect on one or more PSCs
Directive 2012/34 requires that international rail services may be limited to protect the
economic equilibrium of a PSC
Member States or competent authorities may selectively waive the powers to grant
exclusive rights or restrict services, with the effect that a service may be permitted by one
mode and forbidden by another
C.111 The resulting growing complexity, and the potential liberalisation of the large and often
dynamic domestic coach markets, raises the issue of whether further liberalisation should be
combined with further harmonisation so that the restrictions are independent on the modes
of existing and new services.
Fares
C.112 A further issue relevant to the liberalisation of coach markets is the extent to which
coordination or integration of fares should be permitted or required, which we discuss briefly
below.
C.113 Regulation 1073/2007 Article 4 states that:
“The fact that a carrier offers lower prices than those offered by other road carriers or the fact
that the link in question is already operated by other road carriers shall not in itself constitute
justification for rejecting the application.”
C.114 This explicitly envisages that a carrier offers lower prices, and implicitly assumes that fares are
not inter-available between operators, as is often the case in other modes and is a specific
feature of one model of rail liberalisation.
C.115 In most Member States, a single national and publicly-owned rail operator has been
responsible for all domestic services and has provided a consistent approach to fares including
common types and conditions of ticketing and the sale of through tickets between any two
points in the network. Under progressive rail liberalisation since 1988 (in Sweden) there has
been considerable divergence from this model, including variations such as:
Each operator is free to devise and set their own fares, and no through fares exist.
Through fares must be offered and “inter-available” (accepted by all operators), but
operators are allowed to offer lower fares on their own services.
Long-distance fares are not regulated, but operators of long-distance services must accept
locally-priced tickets for short distance journeys.
C.116 Airlines in the global aviation market have found that it is commercially valuable to have
“interline” agreements to enable them to offer through fares and through baggage services.
Great Britain’s railway requires that fares are available between any two stations, and are
accepted by all operators, and imposes processes for apportioning the revenue to operators.
C.117 Some domestic coach markets are not highly regulated but in others, particularly with an
incumbent national operator, there may be an expectation that through and inter-available
fares will be available.
C.118 We conclude that action to liberalise coach services may, as with the Fourth Railway Package,
need to consider:
Whether fares offered by different operators should be liberalised, regulated or
integrated
Whether integrated ticketing between coach operators should be forbidden, permitted or
mandated
Whether integrated ticketing between coach and other modes should be forbidden,
permitted or mandated
Monitoring and information provision
C.119 Our 2009 study identified that one of the principal difficulties of studying the long-distance
coach market was the lack of reliable, consistent and comprehensive information on coach
operations. This included not only detailed information on customer satisfaction (we noted
that private companies have no obligation or indeed incentive to publish service quality
indicators96) but also basic information on fleets, operations, passengers, revenues and costs.
C.120 Other studies for the Commission have also revealed a consistent lack of reliable information
in other transport sectors. For example:
In a current study on the impact of Regulation 1370/2007, our Draft Final Report noted
that limited requirements for competent authorities to require, or Member States to
collate, information on PSO bus, light rail and urban rail services means that it is difficult
to form a view of the operation and financing of the sector.
In a recent study of the harmonisation of cost allocation for Air Navigation Service
Providers (ANSPs), we found that general principles for the allocation of costs had
resulted in widely different approaches in practice.
In our work on the Fourth Railway Package, we noted that subcontracting, liberalisation
and privatisation all make it harder, not only in practice but also in principle, to define the
boundaries of an industry and hence its financial and operational data.
C.121 However, processes exist by which data can be standardised, anonymised to protect
confidentiality, and collated on a basis which allows the effective monitoring of the
operations, finances and performance of an industry. In some cases this is carried out by a
specialised industry body on a basis agreed by members or subscribers, as is the case with
OAG which monitors the aviation industry. It may therefore be appropriate to consider
regulation to require consistent provision of certain information by all coach operators,
subject to the observations that:
The requirement to provide information should be proportionate and have due regard to
legitimate concerns regarding commercial confidentiality.
Clear definitions are likely to be required, as the example of the costs of ANSP provision
show: one approach is for data collection standards to be agreed within the industry
rather than imposed externally.
96
“Study of passenger transport by coach”, 4.70
D Stakeholder engagement
Introduction
D.1 The Task Specification required the delivery of a robust stakeholder engagement process
under the guidance of the Commission and according to the Commission’s minimum standards
for consultation.
D.2 Our study methodology is based on two separate approaches to data gathering and analysis,
designed to ensure an appropriate balance in terms of pan-European coverage on the one
hand and in-depth investigation and analysis of issues arising in particular markets on the
other. It involved:
A combination of desk research and telephone interviews covering all 28 Member States,
undertaken by team members with appropriate language and relevant sector expertise in
order to understand the issues, identify the relevant stakeholders, identify experts, collect
data and find sources of information; and
Detailed case studies of 10 Member States, which built on the information obtained in the
previous stage through face-to-face interviews with a number of stakeholders in each of
the selected countries in order to obtain specific and detailed information rather than too
general findings.
D.3 The selection of Member State case studies was intended to provide a representative sample
of countries with a range of characteristics in terms of level of economic development,
population density, geographical location and models of competition and regulation. We also
considered two examples of international coach operations in order to illustrate perspectives
that Member State coverage alone would not capture.
Stakeholder consultation
Objectives of the engagement with stakeholders
D.4 The objectives of the engagement with stakeholders were to:
Determine stakeholder views on:
the regulatory aspects that rule the coach sector in their country; and
evaluation on the impact of Regulation 1073/2009 on international coach transport.
Enable us to obtain information and data required to provide an overview of coach
transport market in each Member State and for the case study analysis.
Consultation
(EC) No 1073/2009. We also collected specific information about the carriage of disabled
passengers and persons with reduced mobility.
D.12 Team members undertook stakeholder engagement, translating the template into local
languages as required. All stakeholders invited to participate in the interview programme were
initially be contacted by e-mail, with the letter of introduction from the Commission attached.
Once agreement was obtained, stakeholders were sent the questionnaire/data request
templates and, where necessary, an interview date and time was agreed. Interviewers were
asked to capture all responses and make further contact as necessary to clarify information or
ask additional questions.
Stakeholder engagement
D.13 The table below summarises the total number of stakeholders contacted and responses
received in the period to the end of November 2015.
Table D.1: Stakeholders contacted and responding, July to November 2015
D.14 The responses were received in the form of questionnaires sent by email or recorded in
meeting notes.
D.15 The consultation process engaged about 95% of stakeholder groups that we intended to
contact. In some cases competent authorities at the national level correspond to the Ministry,
while in some Member States we did not identify or contact the specific organisation
responsible for broader competition issues.
D.16 Overall 45% of those that we approached replied to our requests. This exceeds the response
rate achieved in a number of recent stakeholder engagement exercises that we have delivered
for the Commission and reflects the importance of stakeholder input to overcome the lack of
comprehensive and/or comparable data on the coach market across the EU.
D.17 Following further consultation with the Commission, we continued to contact and seek
responses from stakeholders up until late February 2016, a few days before this report was
finalised. This report reflects all the stakeholder comments which we have received and been
able to process before its finalisation.
Confidentiality
D.18 A limited number of stakeholders for the case studies agreed to be interviewed on the
condition that their comments remained confidential. As a result, stakeholder views, on good
contracting practice or other issues, are referred to without attribution in this report.
E Glossary
E.1 Appendix Table E.1 lists two letter codes used to refer to Member States.
Table E.1: Member State codes
E.2 Appendix Table E.2 lists a number of other terms used in this report.
Author/originator Reviewer/approver
Dick Dunmore Simon Ellis
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