Interpretation ID: 77-4.38

TYPE: INTERPRETATION-NHTSA

DATE: 11/17/77

FROM: HOWARD DUGOFF FOR JOAN CLAYBROOK -- NHTSA

TO: Charles Wilson; House of Representatives

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your October 19, 1977, letter enclosing correspondence from your constituent, Mr. M. M. Davis, concerning the remanufacture of school buses.

The manufacture that Mr. Davis proposes to undertake would mount an old school bus body on a new school bus chassis. The regulations of the National Highway Traffic Safety Administration that Mr. Davis enclosed in his letter explicitly state that the use of a new chassis in the remanufacture of a motor vehicle results in the manufacture of a new motor vehicle. Such motor vehicle would be required to comply with all safety standards in effect on the date of manufacture of the chassis or final manufacture of the vehicle or any time between those two dates. In the case of a remanufactured school bus using a chassis manufactured after April 1, 1977, the bus would be required to comply with all of the Congressionally mandated school bus regulations that became effective on April 1.

Congress of the United States House of Representatives

October 19, 1977

Joan Claybrook Administrator, National Highway Traffic Safety Administration Department of Transportation

Enclosed is a copy of a letter from Mr. M. M. Davis, Superintendent of the Newton Independent School District in Texas, in which he describes a problem regarding the rebuilding of their school buses.

I would appreciate your examination of the situation to see if the buses in question may be overhauled, as planned, in the Texas Department of Correction and still meet the Federal Safety Standards. Please advise me of your decision.

Thank you for your consideration and assistance.

Charles Wilson

cc: M. M. DAVIS

NEWTON INDEPENDENT SCHOOL DISTRICT

October 10, 1977

Hon. Charles Wilson I am enclosing a copy of the Highway Standard that Mr. Corbell of the State Board of Control and Mr. Biel of Texas Department of Corrections says will keep our Public Schools in Texas from buying new School Bus Chassis and having our old bus bodies rebuilt at Texas Department of Correction which would save from $ 1000 to $ 3500 on each bus.

We have five buses in the Prison System Bus Repair Facility now to rebuild bodies to be remounted on new chassis. This would save us $ 5000 to $ 15,000 on these five buses.

M. M. Davis, Supt. Newton ISD

(Graphics omitted)

GA-9502 GLIDER

NOTE: Frame and Cab height dimensions shown are with std. tires.

DIMENSIONS IN INCHES FOR SINGLE AND TANDEM REAR AXLE APPLICATIONS Cab Maximum CE Typical Maximum Series WB All OL 54 in. 74 in. 86 in. For Applications Std. Cab Cab Reference Only GA9732 255 201 181 169 165 GA9782 308 254 234 222 195

To determine max. AF for physical limitation with 36 inch upper kingpin setting and 5 inch corner deduct 62 inches from effective CA. Additional dimensional restructions of up 46 inches behind the cab for engine transmission (non-sleeper cab only) or up to 14 inches behind the cab for exhaust, air intake or oil filter (sleeper or non-sleeper) must be considered when determining effective CA.