The U.S. Department of Transportation and the Virginia state government agencies do not mandate seat belts on school buses. School bus design, over the years, has focused on providing a safe space without seat belts. School buses are already the safest form of road transportation in the United States and it is quite unclear, when one considers all the impacts, whether the sizable fiscal cost to have seat belts (or three point restraints) leads to increased safety.
Within the Dominion Electric School Bus (ESB) program is a requirement that all participating school systems accept seat belts if they want to participate in the ESB program. As far as can be seen, Dominion has provided no analytical basis for this requirement other than it aligns with their safety culture (even as Dominion’s work trucks and other vehicles have essentially nothing in common with school bus design, usage, and safety characteristics).
ESB legislation (HB75 and SB1096), being considered at this last minute in the Virginia legislature’s last hours, would put into law this restraint requirement.
F. Any school bus associated with an electric school bus project shall be equipped with an active lap-and-shoulder belt occupant restraint system for each designated passenger seating position.
While any parent (count me in on this) has an immediate ‘why aren’t there seat belts for my kids on the school bus’ gut reaction, there is — at best — very unclear analytical basis for this sort of mandate.
And, this is not a minor issue. Adding “an active lap-and-shoulder belt occupant restraint system” will be in range of $10,000 more per each bus, will reduce the number of passengers per bus (thus perhaps increasing the numbers of buses), increase maintenance costs, and reduce bus usage efficiency. With all those costs, at the end of the day, due to the complex set of interactions, the introduction of such restraints might not even save lives.
With about 17,000 buses for Virginia’s public K-12 schools plus thousands of private school buses, the ESB demonstration program’s two sentence line requiring restraint systems could end up creating a 200 million bill for Virginia’s public schools. Again, a $200M requirement that might not serve the interest of providing safer transportation for Virginia’s children.
To summarize:
- Neither the US Department of Transportation nor the Commonwealth of Virginia have a requirement for school bus seat belts/passenger restraints.
- Dominion is requiring them as part of the ESB program without a public policy analysis to justify this.
- This Dominion requirement would create roughly a $200 million (if not greater) additional acquisition cost for school buses across the Commonwealth.
- The Legislature faces a question: should a private entity drive its decision-making about public investments.
- This is a quite complex arena with uncertainty as to whether school bus seat belts pass any reasonable cost-benefit analysis. It is, when all factors are considered, unclear that school bus seat passenger restraints end up in an overall safer transportation system (especially if one considers opportunity costs and other investments to improve safety/reduce risks).
Rather than mandating restraints within the ESB demonstration program, the legislature should mandate a Virginia Department of Education and Department of Transportation study to assess available school bus seat belt cost-benefit analyses so that legislators can consider the issue in the 2021 session.
To be clear, the assessment and cost-benefit analysis might well find the $200M investment to be fully justified. Amid the reality that school system resources are stretched, creating such a mandate without basic due diligence should not happen.