Interpretation ID: aiam4363
Governor's Representative for Highway Safety
Illinois Department of Transportation
2300 S. Dirksen Parkway
Springfield
IL 62764;
Dear Mr. Smith: This responds to your June 9, 1987, letter to me asking whether Sectio 103(d) of the National Traffic and Motor Vehicle Safety Act.; I have enclosed a copy of a March 23, 1976, letter to Mr. Marti Chauvin relating to the preemptive effect of Federal law over a New York State law for 28-inch high seat backs. Please note the discussion in the Chauvin letter relating to State requirements for additional safety features in *public school buses.* under Section 103(d), a State may require a seat back height higher than 20 inches for its public school buses, provided that the vehicles continue to comply with all applicable Federal safety standards.; I will send a copy of this letter to Mr. Larry Wort of your Department whose earlier letter to us asking about our requirements for seat back height and restraining barriers raised also the same preemption issues. Please feel free to contact my office if you have further questions.; Sincerely, Erika Z. Jones, Chief Counsel