Interpretation ID: nht93-2.45

DATE: April 6, 1993

FROM: Dale Moore -- CIC, Hagan Hamilton Insurance & Financial Services

TO: Walter Myers -- Office of Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/2/93 from John Womack to Dale Moore (A41; VSA 103(14); Part 571.3)

TEXT:

I am an insurance broker representing a local college. We presently provide insurance coverage for their automobiles which are used for transportation of students.

One such program involves transportation of high school age students from their homes to the campus and on field trips. This is done with 15 passenger vans which we are told may have to meet federal requirements in order to be leased or purchased from an automobile dealer.

We are of the opinion that since this program is not affiliated with the local high school, nor is it strictly academic, that the "school bus" 10 passenger rule does not apply. I should add that the college is privately owned.

We will appreciate a ruling as soon as possible because of the financial commitment which has to be made to continue this program. I have enclosed course information to assist you in making your decision.

Attachment

Course information on Linfield College and Upward Bound (text omitted).