Interpretation ID: nht90-2.81

TYPE: Interpretation-NHTSA

DATE: June 11, 1990

FROM: Ron Marion -- Sales Engineer, Thomas Built Buses, Inc.

TO: Paul Jackson Rice -- Chief Counsel, U.S. Dept. of Transportation

TITLE: None

ATTACHMT: Attached to letter dated 11-11-77 from James Tydings to Roger Tilton; Also attached to letter dated 12-21-77 from Joseph J. Levin, Jr. to James Tydings; Also attached to letter dated 3-8-91 from Paul Jackson Rice to Ron Marion (A37; VSA 102(14) Part 571.3); Also attached to letter dated 5-10-82 from Frank Berndt (Signature by Stephen P. Wood) to Martin V. Chauvin; Also attached to letter dated 5-12-81 from Frank Berndt to Doris Perlmutter

TEXT:

This letter is in reference to a recent telephone conversation between Mr. Morris Adams of Thomas Built Buses and Ms. Dee Fujita of your office.

We at Thomas Built Buses would like to request a ruling on an issue which continues to surface in the school bus industry.

With an increasing number of families in which both parents work full-time jobs, more and more children are being placed in privately owned and operated pre-primary school type facilities.

As referenced in the attached letter, the NHTSA has determined that buses purchased to transport pre-primary Headstart children to and from school and related events should be "School Buses" (within the scope of the bus definition . . . designed for carr ying more than 10 persons).

My question is, does this same ruling also apply to the privately owned and operated pre-primary facilities?

Thank you for your assistance in this matter.