Interpretation ID: 2860o
Breda Transportation, Inc.
275 Madison Avenue, Suite 1711
New York, NY 10016
Dear Mr. Cuzzi:
This responds to your letter asking whether buses with a gross vehicle weight rating (GVWR) greater than 10,000 pounds are excluded from coverage under Federal Motor Vehicle Safety Standard No.301, Fuel System Integrity. I regret the delay in responding to your letter.
The answer to your question is yes. Safety Standard No. 301 applies to new passenger cars, multipurpose passenger vehicles, trucks, and buses having a GVWR of 10,000 pounds or less and to all new school buses. The buses you manufacture for sale as municipal transit buses are excluded from Standard No. 301 because their GVWR is greater than the 10,000 pound limit established for the standard.
You asked also whether there are any other Federal standards that might apply to the fuel tanks on your transit buses. I have forwarded a copy of your letter to the Federal Highway Administration (FHWA) and the Urban Mass Transit Administration (UMTA) for their direct reply as to the applicability of any FHWA or UMTA regulations to your transit vehicles. You might also contact the Environmental Protection Agency (EPA) to see whether that agency has any requirements affecting the fuel tanks on your buses. The general telephone number for the EPA is (202) 382-2090.
Sincerely,
Erika Z. Jones Chief Counsel
ref:301 d:6/17/88