I would like to advise that the LPSV Licensing Regulations do not apply to LPSVs owned and operated by a statutory transport undertaking.
Under the Public Transport Regulation Act 2009, PSO bus services which hold Public Service Contracts are generally exempt from standard bus route licencing requirements. PSO services are socially necessary but financially unviable services which are subsidised by the taxpayer. While exempt from the licensing requirements of an LPSV, they must abide by all other road safety regulations and abide by the terms of their public service contract with the National Transport Authority.
Bus Éireann is a statutory transport undertaking and operates both Public Service Obligation services funded by the State subvention and Expressway intercity services which operate on a commercial basis and do not receive any State subvention.
S.I. No. 192 of 2017 -Road Traffic (Large Public Service Vehicles) (Licensing) Regulations 2017
applies to large public service vehicles other than large public service vehicles owned and operated by a statutory transport undertaking.
For further information on this question, I have referred your query to Bus Éireann for direct reply. Please contact my office if you do not receive a reply within 10 working days.