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Interpretation ID: nht88-1.38

TYPE: INTERPRETATION-NHTSA

DATE: 02/11/88

FROM: JERRY SMITH -- MINNESOTA BODY AND EQUIPMENT CO

TO: SHARON L. FORD -- HEAD START DIRECTOR SOUTHEAST IOWA ACTION ORGANIZATION, INC.

TITLE: FEDERAL INTERPRETATION OF SCHOOL BUS USER'S

ATTACHMT: ATTACHED TO LETTER DATED 08/26/88 TO R.C. ROAST FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 108; LETTER DATED 03/18/88 TO CHIEF COUNCIL -- NHTSA, FROM R C ROST RE REQUEST THAT HEADSTART BUSES NOT BE REQUIRED TO HAVE ROOF WARNING LIGHTS IF A COLO R OTHER THAN SCHOOL BUS YELLOW IS USED, OCC - 1763; LETTER DATED 12/21/77, TO JAMES TYDINGS FROM JOSEPH J LEVIN; LETTER DATED 02/25/88 TO SHARON FORD, FROM JERRY SMITH; UNDATED BROCHURES ON SCHOOLBUS BY WAYNE CORPORATION

TEXT: Dear Sharon:

As per our telephone conversation of February 9, 1988, I am enclosing copies of communications regarding and/or effecting what type of bus that can be sold to, or purchased by the Head Start organization.

Please note that this is not Minnesota Body Company's policy, nor is it our wish to cause you any inconvenience. However, due to the interpretation by the U.S. Department of Transportation, we are bound to provide a vehicle that meets all applicable sch ool bus criteria including warning lights CATCH 22. I further realize that warning lights are not allowed in Iowa for non-school use. Therefore, the warning lights would have to be removed or de-activated before you placed the bus in service.

Please let me know if you have any questions, or if I can be of further service

Sincerely,

Dear Sharon,

I have contacted the following people in an effort to resolve the interpretation of school bus user's etc.

Dwight R. Carlson Assistant Chief Bureau of School Administration and accreditation Grimes State Office Bldg Des Moines, Iowa 50319-0146 (515) 281-5811

J.P. Golinvaux District Representative Iowa Department of Transportation Air and Transit division State Capitol Des Moines, iowa 50319 (515) 281-4265

Jerry Smith