ID: 19867.wkm

Mr. Keely Brunner
Customer Relations and Contract Compliance
Transportation Techniques "Trans Teq"
1705 East 39^th Avenue
Denver, CO 80205

Dear Mr. Brunner:

This responds to your e-mail inquiry of April 14, 1999, in which you stated that you are a start-up manufacturer of a hybrid-electric bus for a downtown pedestrian mall. You stated that the bus has a maximum speed of 30 miles per hour and a gross vehicle weight rating (GVWR) of 46,000 pounds. You cited paragraph S5.1.2 of Federal Motor Vehicle Safety Standard (Standard), No. 120, Tire selection and rims for motor vehicles other than passenger cars (copy enclosed) and asked whether, since your bus cannot attain a speed of 80 kilometers per hour in 3.2 kilometers or less or 50 mph in 2 miles or less, S5.1.2 applies to your bus. The answer is no.

Paragraph S5.1.2 provides that except for vehicles that are unable to reach a speed of 80 kmh in 3.2 km or reach a speed of 50 mph in 2 miles, the sum of the maximum load ratings of the tires fitted to an axle system must be not less than the gross axle weight rating (GAWR) of the axle system. The GAWR is stated on the vehicle certification label required by 49 Code of Federal Regulations (CFR) Part 567. Paragraph S5.1.2 specifies other requirements, but since your bus has a maximum speed of only 30 mph, none of the requirements of S5.1.2 would apply to your bus. The remaining provisions of Standard No. 120, however, do apply to your bus.

It is not clear from your incoming e-mail whether Trans Teq has manufactured, sold, or delivered any vehicles into interstate commerce. If so, we have no record of Trans Teq having submitted to this agency the information required by 49 CFR Part 565.7(d) (copy attached). Further, if Trans Teq began manufacturing vehicles more than 30 days ago, we have no record of it meeting the reporting requirement of 49 CFR Part 566.6 (copy attached). Please submit the required information without delay.

I am enclosing for your further information a fact sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment," which discusses other pertinent requirements of the Federal motor vehicle safety standards.

I hope this information is helpful to you. Should you have any questions or need additional information, feel free to contact Walter Myers of my staff at this address, by telephone at (202) 366-2992 or by fax at (202) 366-3820.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref:120
d.6/23/99

ID: 1986y

Mr. Takayoshi Chikada
Manager of Automotive Lighting
Engineering Control Dept.
Stanley Electric Co., Ltd.

FAX 03-792-0007 (Japan)

Dear Mr. Chikada:

This is in reply to your letter of June 16, l989, to Mr. Van Iderstine of this agency, by FAX as you requested. You have asked four questions with respect to the recently amended Federal Motor Vehicle Safety Standard No. l08.

We responded to your first two questions in a letter dated June l9 to Mr. Hasegawa of your office. A copy is enclosed for your reference. Since that time, however, in response to a petition by General Motors, we have changed the effective date of paragraph S7.7.5.1(a) to December l, l989, with respect to replaceable bulb headlamp systems. A copy of this notice is also enclosed.

Your third question is:

How should we prove the confirmation to the requirement of S7.7.2.2? We think the combination of Horizontal and Vertical angle within the aim range will be so huge and it is not practicable to test for all combinations.

This paragraph applies to headlamps aimed by moving the reflector relative to the lens and headlamp housing, or vice versa. The agency has frequently advised manufacturers that there is no legal requirement that conformance be demonstrated through the test procedures stated in the standard. While the agency will use those procedures in its compliance testing, the manufacturer may certify compliance with the performance requirements of a standard through engineering studies, computer simulations, mathematical calculations, or other means intended as an exercise of due care and affording a reasonable basis upon which to certify compliance. Your final question is:

It is acceptable to set up initial "0" point of S7.7.5.2(a)(2) not mechanically but photometrically?

You may determine the "O" point by whatever means you deem appropriate for the headlighting system, as long as the method achieves a horizontal "O" point that may be used for the purposes of paragraph S7.7.5.2(a)(2), and any other paragraph in which the horizontal "O" mark is required to be determined.

In the future, please address your requests for interpretations of Standard No. l08 to this office.

Sincerely,

Stephen P. Wood Acting Chief Counsel

Enclosure

ref:l08 d:8/23/89

ID: 19873.ztv

Mr. Daniel R. Todd
Muth Mirror Systems
4221 High Tech Lane
Sheboygan, WI 53082-0418

Dear Mr. Todd:

This is in reply to your e-mails of April 15 and April 19, 1999, requesting confirmation that an interpretation that this Office provided John K. Roberts of Muth Mirror Systems on January 15, 1991, with respect to a "Stop Turn Mirror" ("STM") is valid also for a revised version of that device.

The original STM was designed to appear as a mirror to the vehicle operator, but as a stop and turn signal indication system to the operator of a vehicle following. Your current "Signal Mirror" provides a "high intensity chevron shaped signal which is mounted behind and projects through the mirror," and is operated by the turn and hazard warning signal system. That is to say, the chevron signal in the exterior rearview mirror on the driver's side of the vehicle will indicate a left turn, and the chevron signal in the exterior rearview mirror on the passenger side of the mirror will indicate a right turn. Both chevron signals will activate simultaneously when the hazard warning signal is activated.

You are also developing a "high extended mount stop lamp" (HEMSL) which is operated when the brakes are applied; this feature consists of "a straight line of high intensity lamps" centered near the top edge of the mirror, which also "are mounted behind and project through the mirror surface." As you explained to Taylor Vinson of this office on May 24, the stop signal will appear simultaneously in both exterior mirrors. You have asked us four questions about how our 1991 letter applies to these two new mirrors.

The first question relates to Federal Motor Vehicle Safety Standard No. 108's prohibition of combining a center high mounted stop lamp (CHMSL) with any other lamp or reflective device. We advised in 1991 that a mirror was not a reflective device for purposes of Standard No. 108, and that the question would be whether the turn signal functions of the STM were clearly separated from the stop function so that the question does not arise as to whether they are combined. You have asked "Based on the updated device description provided above and current code interpretation, does the Chief Counsel's remarks still stand."

The original STM provided a stop signal through the interior rearview mirror, whereas the new mirror system provides a stop signal through the two exterior mirrors. The stop signals are supplementary to the stop lamps that are mounted on the rear of the vehicle. Paragraph S5.4 Equipment combinations of Standard No. 108 does not prohibit combining stop lamps, other than CHMSLs with other lighting devices. The question that must be answered with respect to supplementary lighting equipment is whether they impair the effectiveness of lighting equipment required by Standard No. 108. With respect to the Muth mirror, we do not conclude that such an impairment exists. This also answers your final question: whether the stop and turn signal function may be combined in the Signal Mirror alone which does not incorporate a CHMSL. The answer is yes; Standard No. 108 does not prohibit the combining of supplementary stop and turn signal/hazard warning signal lamps.

Our 1991 letter also discussed the possibility of the STM replacing the original equipment CHMSL. We advised that the STM could not do so if it were intended to be located in the exterior rear view mirrors rather than the center interior mirror. This is the configuration of your HEMSL. Thus, the supplementary stop lamp HEMSL may not replace the original equipment CHMSL.

You next ask "If the HEMSL, mounted in the exterior rear-view mirrors, provided a certain geometric visibility and photometric output such that it contributed to the required CHMSL visibility and photometric standard, in this theoretic system of three lamps, could the lamp mounted on the centerline have its geometric and photometric requirements tailored such that when combined with the HEMSLs and provided the overall CHMSL requirements indicated in Standard No. 108?" The answer is no; Standard No. 108 requires that there be a single, not multiple, lamp comprising the CHMSL, and that that single CHMSL meet all specified photometric and visibility requirements, and not share them with an array of three lamps.

If you have further questions, you may phone Taylor Vinson (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.6/14/99

ID: 1987y

Mr. Michael E. Kastner
National Truck Equipment
Association--Washington Office
1350 New York Avenue, N.W., Suite 800
Washington, D.C. 20005-4797

Dear Mr. Kastner:

Thank you for your letter to Secretary Skinner concerning the National Highway Traffic Safety Administration's (NHTSA's) actions to extend certain Federal Motor Vehicle Safety Standards (FMVSS's) to light trucks and vans. The Secretary has asked me to reply.

Your letter was especially concerned with NHTSA's November 1987 amendment to FMVSS 204, Steering Control Rearward Displacement, and our denial of NTEA's petition for reconsideration of that rule. I regret that I am unable to respond to your comments at this time. As you know, the Department and NTEA are presently involved in litigation concerning those actions. In view of the litigation, we feel it would be inappropriate to address your comments in this letter.

We appreciate your interest in informing the Department of your views. I can assure you that Secretary Skinner is actively interested in each of the letters he receives regarding NHTSA's mission to improve motor vehicle safety. Let me assure you also that the potential impacts on small businesses is one of our concerns in each of our rulemaking actions.

A copy of your letter, and this response, will be placed in NHTSA's docket section.

Sincerely,

Jeffrey R. Miller Acting Administrator ref:204 d:8/22/89

ID: 19882.drn

Pastor Carlo DeStefano
Fairwinds Baptist Church
801 Seymour Road
Bear, DE 19701

Dear Pastor DeStefano:

This responds to your April 14, 1999, letter requesting information on Federal statutes governing school bus safety. Dorothy Nakama of my staff spoke to your secretary, who informed us that your church operates Fairwinds Christian School, which teaches students from kindergarten through twelfth grade. Ms. Nakama was informed that you seek information about the school bus safety laws administered by the National Highway Traffic Safety Administration (NHTSA) to determine what your responsibilities are when transporting your students.

I am pleased to provide the following information. NHTSA is authorized to issue and enforce Federal motor vehicle safety standards applicable to new motor vehicles. Our statute at 49 U.S.C. 30112 requires any person selling or leasing a new vehicle to sell or lease a vehicle that meets all applicable standards. Accordingly, persons selling or leasing a new "school bus" must sell or lease a vehicle that meets the safety standards applicable to school buses. Our statute defines a "schoolbus" as any vehicle that is designed for carrying a driver and more than 10 passengers and which, NHTSA decides, is likely to be "used significantly" to transport "preprimary, primary, and secondary" students to or from school or related events. 49 U.S.C. 30125. By regulation, the capacity threshold for school buses corresponds to that of buses -- vehicles designed for carrying more than ten (10) persons. For example, a 15-person van that is likely to be used significantly to transport students is a "school bus."

Our statute thus regulates primarily manufacturers and sellers of new school buses. Any person selling a new school bus must sell a vehicle that is certified as meeting our school bus standards. Conventional buses (including 15-passenger vans) are not certified as doing so, and thus cannot be sold, as new vehicles, under circumstances where they are likely to be used to carry students on a regular basis.

In general, our school bus safety statute does not regulate school bus users. Instead, each State has the authority to set its own standards regarding the use of motor vehicles, including school buses. You should check Delaware law to see what your State law requires when your private school transports its students. For information on Delaware's requirements, you can contact Delaware's State Director of Pupil Transportation:

Mr. Ronald Love, State Supervisor, School Transportation
Delaware Department of Education
P. O. Box 1402
Dover, DE 19903
Telephone: (302) 739-4696

In closing, we wish to emphasize that school buses are one of the safest forms of transportation in this country, and that we therefore strongly recommend that all buses that are used to transport school children be certified as meeting NHTSA's school bus safety standards. Further, using buses that do not meet NHTSA's school bus standards to transport students could result in increased liability in the event of a crash. Since such liability would be determined by State law, you may wish to consult with your attorney and insurance carrier for advice on this issue.

I hope this information is helpful. For more information about the safety features of a school bus, I am enclosing NHTSA's publication: "School Bus Safety: Safe Passage for America's Children." If you have any further questions please feel free to contact Dorothy Nakama at this address or by telephone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:VSA#571.3
d.5/25/99

ID: 19883.wkm

Tim Broten, President
Skiddd Wheel Indicator
Box 129
Starbuck, Mb.
ROG 2PO
CANADA

Dear Mr. Broten:

Your letter to Mr. Ron Evenson, State Director, Office of Motor Carrier Safety, Bismarck, North Dakota, was forwarded to this agency for reply.

You stated in your letter that your company produces the Skiddd wheel lock indicator that is described as a strip of special nylon plastic that is attached to the wheel stud of a truck. The Skiddd protrudes out from the wheel about two inches, which allows the driver to see from his rear view mirror whether the wheel is turning. The intent is to permit the driver to determine from the truck cab whether the wheels are in fact turning or whether one or more of them are skidding. You asked for a "letter of approval" to indicate that the Skiddd indicator complies with applicable safety standards.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the statutory authority to issue Federal motor vehicle safety standards (FMVSS) applicable to new motor vehicles and new items of motor vehicle equipment. Federal law establishes a self-certification system under which motor vehicle and equipment manufacturers themselves certify that their products comply with all applicable FMVSSs. For that reason, NHTSA neither tests, approves, disapproves, endorses, nor grants letters of approval of products prior to their introduction into the retail market. Rather, we enforce compliance with the FMVSSs by purchasing vehicles and equipment and testing them. We also investigate safety-related defects.

Turning now to the Skiddd wheel lock indicator, we would classify it as an item of motor vehicle equipment, defined in 49 U.S. Code (U.S.C.) 30102(a)(7)(B) as any "part or component manufactured or sold for replacement or improvement of a system, part, or component, or as an accessory or addition to a motor vehicle." Specifically, the Skiddd wheel lock indicator is an accessory if it meets the following criteria:

a. A substantial portion of its expected uses are related to the operation or maintenance of motor vehicles; and

b. It is purchased or otherwise acquired, and principally used by ordinary users of motor vehicles.

After reviewing your letter and its enclosed product brochure, we conclude that the Skiddd wheel lock indicator is an accessory. It was designed with the expectation that a substantial portion of its expected use will be with motor vehicles. Further, the pictures of the Skiddd in the brochure make it clear that the wheel lockup indicator is intended to be purchased and principally used by ordinary users of motor vehicles, mostly truck drivers, to continuously monitor whether their wheels are turning properly.

While the Skiddd wheel lock indicator is a motor vehicle accessory, NHTSA has not issued any FMVSSs establishing performance standards applicable to this product. However, the manufacturer, whether you or a licensee, is subject to the requirements of 49 U.S.C. 30118 - 30121 (copies enclosed) which set forth the recall and remedy procedures for products with defects related to motor vehicle safety. Thus, if NHTSA or the manufacturer determines that the product contains a safety-related defect, the manufacturer is responsible for notifying purchasers of the defective equipment and for remedying the problem free of charge to the consumer.

Additionally, 49 U.S.C. 30122 (copy enclosed) provides that a manufacturer, distributor, dealer, or vehicle repair business may not knowingly "make inoperative" any device or element of design installed on or in a motor vehicle in accordance with any FMVSS. Therefore, the Skiddd could not be installed by one of those entities if such use would adversely affect the compliance of a vehicle with any FMVSS. This provision does not apply, however, to equipment attached to or installed on or in a vehicle by the vehicle owner.

I note that the Department's Office of Motor Carrier Safety has jurisdiction over interstate motor carriers operating in the U.S. On August 18, 1999, the Vehicle and Operations Division of that agency responded to your inquiry about using the Skiddd indicator on commercial motor vehicles. We have coordinated this response through the Acting Director of the Office of Motor Carrier Safety.

For your further information, I am enclosing a fact sheet we prepared entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment, and Where to Obtain NHTSA's Safety Standards and Regulations.

I hope this information is helpful to you. If you have any questions or need additional information, feel free to contact Edward Glancy of my staff at this address, by telephone at (202) 366-2992, or by fax at (202) 366-3820.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures

cc: Mr. Ronald O. Evenson
State Director
Office of Motor Carrier Safety
1471 Interstate Loop
Bismarck, ND 58501

ref:119
d.11/23/99

ID: 19884.ztv

Mr. Ron Woodward, P.E.
Section Supervisor Optics & Adv. Eng.
Federal Mogul
2513 58^th Street
Hampton, VA 23661

Dear Mr. Woodward:

This is in reply to your letter of April 19, 1999, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment as it applies to a proposed horizontal alignment system for use with visual/optical aim headlamps.

Paragraph S7.8.2.1(c) of Standard No. 108 states that "A visually/optically aimable headlamp that has a lower beam shall not have a horizontal adjustment mechanism unless such mechanism meets the requirements of paragraph S7.8.5.2 of this standard." You reference previous interpretations of this office which state "that disabled horizontal adjusters are acceptable [i.e., are not horizontal aim mechanisms within the meaning of the phrase]," that "certain types of anti-tamper screws are not permitted" ("ones that can be driven in one direction"), but not all types of such screws, and "exposed screw heads were also rejected because pliers could be used to rotate the screw."

You have enclosed a drawing showing a horizontal alignment system that you propose to use. It "would be used during manufacturing to achieve proper mechanical alignment of the mounting surface and lamp optical system and is not meant to be adjustable after manufacture." The drawing you enclose shows both a plan and section view of your system. There is an "external shroud [which] prevents adjustment by wrenches and pliers." There is also a center section described as "center anti-tamper post [which] prevents entry of standard Torx driver bit, screw driver, & Allen wrench." You ask whether we would regard this as a horizontal adjustment mechanism as prohibited by S7.8.2.1(c).

Yes, we would regard this design as a horizontal aim mechanism within the meaning of S7.8.2.1(c)(and impermissible because it does not meet S7.8.5.2). Although the center anti-tamper post prevents entry of a standard Torx driver bit, non-standard Torx driver bits are readily available which would defeat your intent that the horizontal alignment not be adjustable after manufacture. Specifically, SK Drive Tamper-Proof Torx Bits are available through internet web sites, if not tool jobbers and mobile tool sales outlets, and these are intended to fit the center anti-tamper post and allow entry.

If you have any questions, you may phone Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.6/28/99

ID: 19886.ztv

David H. Coburn, Esq.
Steptoe & Johnson LLP
1330 Connecticut Avenue, NW
Washington, DC 20036-1795

Re: Request for Clarification

Dear Mr. Coburn:

This is in reply to your letter of April 16, 1999, seeking a confirmation that a previous interpretation of Federal Motor Vehicle Safety Standard No. 108 remains valid.

The interpretation is one that we sent your client, Baran Advanced Technologies, Ltd., on September 7, 1993. In that letter, we informed Baran that we did not believe that a device which activates a vehicle's hazard warning system upon sensing a sudden release of the accelerator pedal would impair the effectiveness of the stop, tail, and turn signal lamps required by Standard No. 108, assuming that the device is not activated under normal stopping conditions, that it is automatically deactivated when the brake pedal is applied, that manual deactivation is not required, and that the device would be overriden by manual activation of the turn signal lamps.

Regrettably, I cannot confirm that this interpretation remains valid. Our earlier interpretation did not consider the effect of the device upon the hazard warning signal itself. Since 1993, we have come to the conclusion that use of required lighting equipment for other than its original purpose may compromise and reduce its safety effectiveness. As we said in 1996,

It is important that the integrity of the required signal lamps be maintained, and that auxiliary signal lamps not detract attention from the messages that the required signal lamps are sending. A vehicle signaling system must be as simple and as unambiguous as possible to others who share the roadway if traffic is to proceed in a safe and orderly fashion. (61 FR 65516)

See also our Statement of Policy published in the Federal Register on November 4, 1998 (63 FR 59482, copy enclosed).

We believe that a hazard warning system should not be used for the auxiliary purpose of indicating sudden accelerator release, a signal that bears no relationship to a hazard warning signal and one which could create confusion were the hazard warning signal used for an unrelated purpose. We believe that our 1993 interpretation was superseded by our subsequent policy statement, and therefore reverse it and conclude that S5.1.3 prohibits the system as described.

If you have any questions, you may call Taylor Vinson (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref.108
d.8/6/99

ID: 1988y

Mr. Dan Trexler
Specifications Engineer
Thomas Built Buses, Inc.
P.O. Box 2450
High Point, NC 27261

Dear Mr. Trexler:

This is in reply to your letter of May 8, l989, to the former Chief Counsel of this agency, Erika Jones. You have received requests "to install a master electrical disconnect switch on many buses." When the switch is turned to the "off" position "it renders inoperative the warning signals (to the driver) required by FMVSS l05, 121 and 217. It also inactivates the hazard warning flasher required by FMVSS l08." You ask whether installation of the switch would constitute a noncompliance, or a "safety related hazard." if it is accessible to the seated driver, or if remotely located in the battery or engine compartment, without ready access to the driver.

Although you have not explained the purpose of such a device, we understand that a battery disconnect switch of this nature is deemed desirable by many bus owners to prevent drains on the battery when the bus is at rest. When the switch is activated, the bus cannot be started and driven because electric power is not available. Under this circumstance we do not believe that the switch either creates a noncompliance with any of the standards listed, nor constitutes a safety related defect, regardless of its location. When the bus is in operation the warning systems of the standards are not affected. The possibility of inadvertent activation when the bus is in use does not constitute a defect in performance, construction, components, or materials such as to create a safety related defect. To forestall any possibility of inadvertent activation, however, you may find it preferable to locate the switch away from the driver.

We understand that a purpose of this switch is to reduce the likelihood of fire after accidents in which there has been fuel spillage. In this circumstance, it is likely that the bus would be positioned either in the roadway or adjacent to it. Safety would be enhanced if the hazard warning signal power source were separate from the batteries inactivated by the disconnect switch, so that these warning lamps could continue to operate.

Sincerely,

Stephen P. Wood Acting Chief Counsel / ref:VSA#l04#l08#l2l#2l7 d:8/30/89

ID: 19891.drn

Mr. Dennis Seavey
Plus Time New Hampshire
160 Dover Road, Suite One
Chichester, NH 93234

Dear Mr. Seavey:

This responds to your letter asking about our August 8, 1998, interpretation to Mr. Terry L. Voy, School Transportation Consultant for the Iowa Department of Education, concerning our school bus regulations.

In the letter to Mr. Voy, we explained that persons selling a new bus to a daycare facility must sell a "school bus" if the bus will be significantly used to transport school children to or from school or related events. As to whether a bus is "used significantly" for such use, we told Mr. Voy that regular use of a bus to pick up students from school five days a week would constitute "significant use" as a school bus. We also stated in that letter that "regular use on alternate days would be 'significant.'"

You ask about the latter statement, as to whether transporting school-aged children to and/or from a child care facility and school three days a week (Monday, Wednesday, and Friday) constitutes "significant use" as a school bus. You also ask if we would consider the bus to be "significantly" used for school transportation if it were used to take children to and/or from school on Tuesdays and Thursdays.

Our answer is that regular use of the vehicle to transport school children to or from school on Mondays, Wednesdays, and Fridays, or on Tuesdays and Thursdays, is "significant use" of the vehicle for school transportation. We would also consider transportation provided to or from school on any two days during a week to be regular use and therefore "significant."

As you are aware, the National Highway Traffic Safety Administration's (NHTSA) safety standards directly regulate the manufacture and sale of new motor vehicles, not their use. Each state has the authority to set its own standards regarding use of motor vehicles, including school buses. Please check with the appropriate New Hampshire officials to see if any State law regulates how New Hampshire school children must be transported between their school and after school programs. For information on New Hampshire's requirements, you may contact New Hampshire's State Director of Pupil Transportation:

Ms. Bethia LaMarca, Pupil Transportation Supervisor
New Hampshire Department of Safety
10 Hazen Drive
Concord, NH 03305
Telephone: (603) 271-1999

In closing, we wish to emphasize that school buses are one of the safest forms of transportation in this country, and that we therefore strongly recommend that all buses that are used to transport school children be certified as meeting NHTSA's school bus safety standards. Further, using 15-person vans that do not meet NHTSA's school bus standards to transport students could result in increased liability in the event of a crash. Since such liability would be determined by State law, you may wish to consult with your attorney and insurance carrier for advice on this issue.

I hope this information is helpful. I am enclosing NHTSA's publication: "School Bus Safety: Safe Passage for America's Children" that describes the safety features of a school bus. I am also enclosing NHTSA's February 1999 "Guideline for the Safe Transportation of Pre-school Age Children in School Buses." If you have any further questions please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref:VSA#571.3
d.5/20/99