Interpretation ID: nht92-1.44

DATE: 12/04/92

FROM: RON MARION -- SALES ENGINEER, THOMAS BUILT BUSES, INC

TO: BARRY FELRICE -- ASSOC. ADMINISTRATOR FOR RULEMAKING, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 3-3-93 FROM BARRY FELRICE TO RON MARION (A40; STD. 131)

TEXT: This letter is being written regarding the new Federal Motor Vehicle Safety Standard - 131 school bus pedestrian safety devices.

As a manufacturer of school bus bodies, we are getting numerous questions regarding the installation of stop arms on school buses not used on route service.

A number of schools across the U.S. purchase school buses, paint them a color other than yellow, and use them exclusively for athletic trips. These athletic use buses pick up at the school and travel to another school to unload. They do not make stops for loading or unloading along the way and in no way attempt to control traffic.

The purchasers of this type of "school bus" have a problem with paying for stop arms and in some cases warning lamps which are never used.

My question is, has there been any consideration given to an exemption for this non-route type "school bus"?

Thank you for your assistance in this matter.