Interpretation ID: aiam0114
United States Senate
Washington
DC 20510;
Dear Senator Miller: Thank you for your letter of August 13, 1968, calling my attention t Mr. Paul Johnston's comments and suggestions on the requirements for school bus signal lamps as specified in Motor Vehicle Safety Standard No. 108.; As Mr. Johnston pointed out, Standard No. 108, effective January 1 1969, provides for optional use of either the eight-lamp or four- lamp signal system. This optional provision was adopted after careful consideration of the comments and recommendations which were received in response to the Notice of Proposed Rule Making as published in the *Federal Register* on February 3, 1967. The 'Minimum Standards for School Buses', as published by the National Conference on School Transportation, and the regulations governing minimum standards for school buses in various states were also considered during development of the optional provision for signal lamp systems. Results of our studies and investigations indicated that approximately forty states were using either the four-lamp or eight-lamp signal system. Other states were using the adopted system with only minor variations in the installation and operational requirements.; Standard No. 108, effective January 1, 1969, was published in th *Federal Register* on December 16, 1967. Under the procedural rules of the Federal Highway Administration, any person adversely affected by this order may petition the Administrator under Part 216, Subchapter B, Section 216.31 or Section 216.35, published in the *Federal Register* on November 17, 1967, a copy of which is enclosed. No petition of the adopted requirements for school bus signal lamps has been filed.; Although we do not dispute the safety benefits which Mr. Johnsto claims for a six-lamp system, I must emphasize that our long-range objective is the adoption of one nationwide system. Even with the presently adopted systems, a motorist could be faced with the problem of interpreting two sets of signals during a very short time period. This problem will become more prevalent with the anticipated increase in rapid interstate traffic. To permit the use of a third optional system, six-lamp or other, would further complicate the situation.; Standard No. 108 applies only to new school buses manufactured on o after January 1, 1969. Retrofitting of buses presently in operation is not required. Since Iowa's fleet of buses is presently equipped with a six-lamp system, it appears that considerable data on the effectiveness of this system could be accumulated from this fleet during the next several years, or until such time that a single nationwide system is proposed. We will be pleased to carefully review and consider any such data which Mr. Johnston can provide in the future.; In summary, it is the position of this Bureau that the provision o Standard No. 108 permitting optional use of either the four-lamp or eight-lamp signal system is reasonable, practicable and in the interest of highway safety. Therefore, we do not believe that a change in this provision to permit optional use of a third or six-lamp system is justified.; We have reviewed our files with respect to the written and persona contacts Mr. Arthur Roberts, Director of Pupil Transportation, has had with this Bureau.; This review indicates that the correspondence from Mr. Roberts wa submitted in response to the Notice of Proposed Rule Making on Standard No. 112 (subsequently combined with Standard No. 108) as published in the *Federal Register* on February 3, 1967. It is not the practice of the Bureau to reply individually to the numerous responses received from published rule making notices, which often run to thousands of pages. However, a summary of the comments represented by the responses and the disposition of these comments is presented in the preamble to Standard No. 108 as published in the *Federal Register* on December 16, 1967. With respect to Mr. Roberts' visit on May 7, 1968, the topics of discussion related primarily to the technical requirements of Standard No. 108 and other information relative to the merits of converging Iowa's school buses to either the four-lamp or eight- lamp system. Our understanding was that Mr. Roberts received the information he was seeking at the time of his visit and that no follow-up correspondence was necessary on our part.; Sincerely, William Haddon, Jr., M.D., Director