ID: nht92-9.3

DATE: February 18, 1992

FROM: Wm. Richard Alexander -- Chief, Pupil Transportation, Maryland State Department of Education

TO: Mary Versailles -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/19/92 from Paul Jackson Rice to Wm. Richard Alexander (A39; Std. 222)

TEXT:

In our phone conversation of February 7, we discussed forward-facing wheelchairs on school buses (CFR 49 Part 571.222).

I am requesting that you verify in print our conversation that forward-facing wheelchairs on school buses do not need a crash barrier located forward of each wheelchair position. This would be based on the premise that each chair and child is restrained in some type of a belting system.

If you have any questions prior to responding, please do not hesitate to call me at (410) 333-2602.

ID: 11322MLS

Mr. Alfred Kozak
Product Engineer
Acts Testing Labs, Inc.
25 Anderson Road
Buffalo, NY 14225-4928

Dear Mr. Kozak:

This responds to your inquiry about testing procedures in Federal Motor Vehicle Safety Standard No. 302, AFlammability of Interior Materials.@ In particular, you asked how section S5.1.3, which specifies the use of support wires in certain situations, would apply to fabric material used in a car seat. The short answer is that during NHTSA compliance testing, support wires would be used in testing any specimen that "softens and bends at the flaming end so as to cause erratic burning." However, the agency cannot specify, outside of the context of a compliance test, whether a given type of material falls in this category.

By way of background information, NHTSA is authorized to issue Federal motor vehicle safety standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the applicable statute (49 U.S.C. Chapter 301) establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

You ask about Standard No. 302, which specifies requirements for the flammability resistance of materials in the occupant compartment of new vehicles. Along with specified performance requirements, Standard No. 302 sets forth conditions and procedures under which NHTSA tests materials for compliance with the standard. Section S5.1.3 of the standard states, in relevant part, that:

The test specimen is inserted between two matching U-shaped frames of metal stock 1-inch wide and 3/8 of an inch high. The interior dimensions of the U-shaped frames are 2 inches wide by 13 inches long. A specimen that softens and bends at the flaming end so as to cause erratic burning is kept horizontal by supports consisting of thin, heat resistant wires, spanning the width of the U-shaped frame under the specimen at 1-inch intervals. A device that may be used for supporting this type of material is an additional U-shaped frame, wider than the U-shaped frame containing the specimen, spanned by 1--mil wires of heat resistant composition at 1-inch intervals, inserted over the bottom U-shaped frame.

Please note that NHTSA uses supplemental wires when there is a reasonable expectation that a test specimen will soften and bend so as to cause erratic burning. The agency bases its determination about the likelihood of this condition on observations made in previously-conducted compliance tests of the specimen, or on the agency's knowledge of or testing experience with components that are highly similar to a test specimen. However, since a decision to use wires is made only in the context of compliance testing, we regret that we cannot tell you at this time whether support wires would be used to test the materials about which you are concerned.

Vehicle manufacturers are not required by Standard No. 302 to test the flammability of their vehicles in the manner specified in the standard. The standard only sets the procedure that the agency will use in its compliance testing. Thus, a vehicle manufacturer is not required to use wires only with specimens that are anticipated to soften and bend so as to cause erratic burning. However, vehicle manufacturers are expected to exercise reasonable care in certifying that their product will meet Standard No. 302's requirements when tested by NHTSA according to the specified procedures of the standard. Whether a vehicle manufacturer has met that reasonable care standard in a particular case involving a noncompliance with the standard is a matter that is determined by the agency only in the context of an enforcement proceeding.

You first ask whether the phrase "softens and bends" applies to plastic materials which sag due to heat and specimen weight or to all materials regardless of composition. Section S5.1.3 specifies the use of a supplemental wire support for "a specimen that softens and bends at the flaming end so as to cause erratic burning." Plastic materials are the most commonly used material that can soften and bend. Nevertheless, the agency emphasizes that the procedure would be used for any material that softens and bends at the flaming end so as to cause erratic burning.

You then ask whether the wire supports are used if the material softens and bends without erratic burning. The test condition noted above should be read as a whole. Therefore, the supplemental supports are only to be used if the specimen (1) softens and bends at the flaming end (2) so as to cause erratic burning.

Your third question asks whether wires are used where the flame front cuts or destroys the specimen in such a way as to allow the specimen to sag similar to the sagging experienced with unsupported specimens. According to the test conditions, supplemental support wires are to be used if the flame front causes the specimen to soften and bend so as to cause erratic burning. Data you provided in your letter showed a wide variation of burn rates between the unsupported and supported specimen tests. The agency would not use support wires in situations of erratic burning alone. The agency would use such support wires only in situations in which the softening and bending occurred prior to erratic burning.

Your fourth question expresses your view that the use of supplemental support wires eliminates Adirectional effects@ and orientation, as discussed in S5.2.2. That provision states that AThe specimen is produced by cutting the material in the direction that provides the most adverse test results. The specimen is oriented so that the surface closest to the occupant compartment air space faces downward on the test frame.@ While it is true that the use of supplemental support wires did reduce the burn rate in your testing of certain material, we interpret the requirements in S5.2.2 as a separate test condition. Thus, the requirements in S5.2.2 are not relevant in determining if a supplemental support wire should be used under S5.1.3.

Your fifth question expresses your view that, by allowing the use of supplemental supports, this test procedure introduces potentially flammable materials into automobile interiors. Specifically, you state that your testing indicated that the burn rate was between 11.5 and 13 inches per minute without supports and 1.8 to 2.1 inches per minute with supports. Please note that the use of support wires is intended to increase the consistency and repeatability of the test procedure, thereby providing a uniform basis for assessing the burn rates of different materials. This is accomplished by reducing sagging which results in erratic burning. Accordingly, we believe that the provision in S5.1.3 relating to the use of support wires provides a reasonable test condition for evaluating the flammability resistance of materials used in motor vehicles.

I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw at this address or by phone at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosure

ref: 302 d:4/16/96

ID: nht90-4.48

TYPE: Interpretation-NHTSA

DATE: October 19, 1990

FROM: Tom Wiatrak -- Century Products Company

TO: Deidre Fujita -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 1-3-91 from Paul Jackson Rice to Tom Wiatrak (A37; Std. 213)

TEXT:

We are enclosing pictures of a suggested location for the warning and instruction labels for a new carseat pad. This surround pad covers the sides of the casting thus hiding the labels installed in the normal position. We would like to add tyvek warnin g and instruction labels sewn to the pad as shown in addition to the labels that appear on the casting.

Please advise at your earliest convenience if this proposal meets the requirements of FMVSS 213.

Attachment

Photos of label location on carseat pad. (Photos omitted.)

ID: aiam4446

"Dear Ms. Whitman: This responds to your letter of September 25, l987 concerning the use of 'steel duck-billed hammers' to change farm and truck tires. You expressed concern that a competitor is using a safety chart produced by NHTSA to support its claim that the use of these tools is prohibited. The NHTSA safety chart, 'Safety Precautions for Mounting and Demounting Tube Type Truck/Bus Tires,' includes two specific references to hammers/hammering. Under the heading 'Deflation and Assembly,' the chart states: 'Never use a steel hammer to assemble or disassemble rim components--Use a lead, brass, or plastic type mallet. Proper tools are available through rim/wheel distributors.' Under the heading 'Assembly and Inflation,' the chart states: 'Never hammer on components of an inflated or partially inflated assembly.' These precautions apply to steel hammers and hammering in general, and the chart does not state that steel duck billed hammers should not be used for other applications in changing tires. We note that you enclosed a copy of a July l3, l987 letter from the Occupational Safety and Health Administration (OSHA), stating the following: OSHA does not prohibit the proper use of a steel duck billed hammer for servicing wheels used on large vehicles such as trucks, tractors, trailers, buses and off-road machines. Under the OSHA regulations at 29 CFR l9l0.l77(d)(6), employers are required to furnish and assure that only tools recommended in the rim manual for the type of wheel being serviced are used to service rim wheels. Further, under 29 CFR l9l0.l77(f)(8), the regulations specify that: No attempt shall be made to correct the seating of side and lock rings by hammering, striking or forcing the components while the tire is pressurized. You state that you are concerned that your competitor's tool may not meet OSHA regulations and may be less than safe to use. We suggest that you contact OSHA about this concern. You may also wish to contact the Federal Trade Commission concerning your belief that your competitor's advertising is misleading. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel";

ID: 24258.drn

Mr. Mark Perez
UniServ Director/Education Support Personnel Specialist
Georgia Association of Educators
100 Crescent Centre Parkway, Suite 500
Tucker, GA 30084-7049

Dear Mr. Perez:

This responds to your question about how Federal law would affect legislation being considered in Georgia that would require upgrades of older public school buses to meet current Federal school bus standards. Our answer is provided below.

In your letter, you state that proposed legislation in Georgia:

would call for all current buses to be modified to include such items as: cross-over mirrors on each bus which shall be adjusted such that the driver may view the front and both sides of the bus from the drivers seat; functioning parking brakes on each bus; and an extension arm or gate on the front of each bus which may be activated by the driver to prevent passengers from crossing immediately in front of the bus.

In a telephone conversation with Dorothy Nakama of my staff, you stated that the proposed legislation would apply only to public school buses that are already owned by the schools or school districts (i.e., used school buses). You further stated that the legislation would apply only to vehicles that, when first sold, were certified by the manufacturer as meeting Federal school bus safety standards. You also asked that we discuss only the proposed legislations requirements for convex-cross view mirrors, parking brakes and crossing control arms.

Mirrors and Parking Brakes

The Federal motor vehicle safety standards (FMVSSs) require that all presently manufactured school buses have convex-cross view mirrors (Standard No. 111, Rearview mirrors) and parking brakes (Standards No. 105, Hydraulic and electric brake systems and No. 121, Air brake systems). Since the school buses that are the subject of the legislation were manufactured before the effective dates of the school bus mirror and parking brake requirements, the proposed legislation would require retrofitting of older buses to meet current requirements.

One issue raised by your inquiry is whether the State legislation would be preempted by Federal law. Our answer is no. The National Highway Traffic Safety Administration (NHTSAs) preemption authority, specified at 49 U.S.C. 30103(b), states in part:

(1) When a motor vehicle safety standard is in effect under this chapter [49 U.S.C. Sections 30101 et seq.], a State or a political subdivision of a State may prescribe or continue in effect a standard applicable to the same aspect of performance of a motor vehicle or motor vehicle equipment only if the standard is identical to the standard prescribed under this chapter. However, the United States Government, a State, or a political subdivision of a State may prescribe a standard for a motor vehicle or motor vehicle equipment obtained for its own use that imposes a higher performance requirement than that required by the otherwise applicable standard under this chapter.

We assume that you are asking about a State provision that would require that only school buses that have the specified school bus mirrors and parking brakes can be operated in the state. Generally, a State is not required to impose operational requirements that are "identical" to the FMVSSs. Nonetheless, there are limits on State operational requirements, in that general principles of preemption law apply. These principles generally preclude States from adopting operational requirements that are more stringent than the requirements applicable to the vehicles under the FMVSSs, because more stringent State requirements would have the effect of precluding the use of a Federally compliant vehicle in that State. However, these preemption principles do not apply to vehicles, such as school buses, procured by a State or local governmental jurisdiction for its own use. Since the legislation you describe would apply only to public school buses, 30103(b) would not preempt the legislation you describe.

Another issue raised by your inquiry is whether NHTSA has any restrictions on the type of modifications that can be made to used vehicles. Nothing in NHTSAs laws would prohibit an owner (i.e., public or private school) from upgrading its used school buses to meet the most current Federal motor vehicle safety standards. The provision in NHTSAs statute addressing modifications of new and used vehicles is at 49 U.S.C. Section 30122(b), which states:

a manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard prescribed under this chapter [49 U.S.C. Section 30101 et seq.] unless the manufacturer, distributor, dealer, or repair business reasonably believes the vehicle or equipment will not be used (except for testing or a similar purpose during maintenance or repair) when the device or element is inoperative.

Section 30122(b) does not apply to an owner modifying its own vehicles. It does not apply to private schools, public schools or public school districts that make changes to their own used school buses in their own bus garages or repair and maintenance facilities. It does apply to other entities, e.g., motor vehicle repair businesses that, in making modifications for a school district, may do so in a way that takes a school bus out of compliance with a FMVSS requirement. For example, FMVSS No. 121 specifies requirements for the time to apply and release the service brakes via the drivers treadle control. If the modifications to achieve functioning parking brakes resulted in a longer time to apply or release the service brakes that exceeded the FMVSS No. 121 requirement, the motor vehicle repair business would be in violation of the aforementioned section.

Crossing Control Arms

No FMVSS specifies crossing control arms on a school bus. NHTSA had considered requiring crossing control arms on school buses to reduce the risk of school buses striking student pedestrians, but decided against doing so:

After reviewing these comments [public comments on an advance rulemaking notice], the agency has determined not to propose requiring these devices on school buses. The agency notes that a crossing control arm does not provide school bus drivers with a positive means for detecting the presence of a pedestrian. Instead, a crossing control arm merely offers a backup device to help keep children in areas more easily observable by the driver. The agency believes that improving mirror systems offers a larger potential benefit to improving school bus pedestrian safety. Nevertheless, States which favor this device should continue to install them on school buses.

See 56 FR 20171, at 20178; May 2, 1991, copy enclosed. Thus, a State requirement for crossing control arms on public school buses would not be preempted.

State Liability Issues

Further, you expressed concern about "potential liability" that could be associated with this proposed legislation. Since the proposed legislation would amend Georgia law, any liability issues would be determined by Georgia law. I would suggest that your organization consult with an attorney knowledgeable about this aspect of Georgia law for advice on potential liability issues.

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address, or at (202) 366-2992.

Sincerely,
Jacqueline Glassman
Chief Counsel
Enclosure

ref:VSA#571.3

d.8/2/02

ID: nht73-4.15

DATE: 05/01/73

FROM: AUTHOR UNAVAILABLE; David Schmeltzer; NHTSA

TO: Varadyne Industries Inc.

TITLE: FMVSR INTERPRETATION

TEXT: As requested in your letter of March 27, enclosed is a copy of the Tire Identification and Record Keeping Regulation. As you will note the regulation is silent as to the question of payment of a fee for registering the tires. I do not think it would be illegal to charge a 50 cent fee for registering tires, however, we would certainly discourage the practice.

ENCLS.

VARADYNE INDUSTRIES, INC.

March 27, 1973

Dr. E. H. Wallace U.S. Department of Transportation National Highway Traffic Safety Administration

Sir:

I request a copy of "The Tire Registration Law". Retail outlet stores in this area are charging 50~ per each Recapped Tire sold as a registration fee. I question their Legal Grounds on this matter and need a copy of the law to solidify my position.

Sincerely,

D. Juve Q. A. Mgr.

ID: nht71-4.3

DATE: 08/11/71

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Long Trailer Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 30, 1971, to Mr. Ed. Leysath of this office concerning the mounting location of side marker and taillights on your boat trailers.

The mounting requirements for lamps and reflectors are specified in Federal Motor Vehicle Safety Standard No. 108 (copy enclosed). It appears as if devices mounted as indicated on your drawing would meet the requirements. If, however, severe problems would be encountered in mounting the devices as indicated or the devices would be subjected to damage during normal use, other mountings may be appropriate and still meet the "as far apart as practicable" or "as far to the rear as practicable" or "as far to the front as practicable" requirements.

If water damage is the only problem when lamps and reflectors are mounted in the indicated positions, special waterproof devices are available and could be used.

ENC.

ID: nht69-2.28

DATE: 08/15/69

FROM: DOWELL H. ANDERS - ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY S. K. BOOTH

TO: Kawasaki Motors Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reference to your letter of July 28, 1969, in which you inquire whether a company that imports motorcycles, performing final assembly in regard to such items as fuel tanks and fenders, may designate itself as the manufacturer for the purpose of the certification regulations, 49 CFR Part 367.

You state in your letter that Kawasaki Heavy Industries, Ltd., the primary fabricator of the motorcycles, assembles the engine and basic frame, wheel and brake assemblies, handlebars, seat, and "some front lighting equipment". The purpose of the manufacturer's designation in the certification regulations is to identify the company that has primary technical responsibility for conformity of the design and quality control of the assembly. It is our opinion, on the basis of the facts presented in your letter, that Kawasaki Heavy Industries, Ltd. is the manufacturer of the motorcycles in question within the meaning of the National Traffic and Motor Vehicle Safety Act and the certification regulations.

You should note, however, that the certification and import regulations do not require that Kawasaki affix the label to the vehicles. The import regulations allow importation of uncertified vehicles in certain cases, such as those where the importer declares that he will bring them into conformity. 19 CFR @ 12.80(b)(2) (iii) and (iv). In regard to such cases, section 367.2(b) of the certification regulations states:

"In the case of imported motor vehicles, the requirement of affixing a label or tag applies to importers of vehicles, admitted to the United States under @ 12.80(b)(2) of the joint regulations for importation of motor vehicles and equipment (19 CFR 12.80(b)(2), to which the required label or tag is not affixed."

Section 367.4(g)(1) requires in such a case that the label affixed by the importer bear both the name of the manufacturer (Kawasaki) and the importer (McCormack). Thus, the net result is that the label affixed by McCormack must bear the name of Kawaski above that of McCormack. Alternatively, Kawaski could affix the label prior to importation, naming only itself as the manufacturer.

We are pleased to be of assistance.

ID: 6960

Marc C. Gravino, Esq.
Williams & McCarthy
P.O. Box 219
Rockford, Ill. 61105-0219

Dear Mr. Gravino:

This responds to your letter of February 7, 1992, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. Specifically, you ask whether the standard contains any requirement that the parking lamps, taillamps, and side marker lamps operate independently of the ignition switch so that when they are activated they will remain activated regardless of whether or not the ignition switch is in the on or off position. You have reviewed Standard No. 108, and reference paragraphs S5.5.3, S5.5.4, S5.5.5, and S5.5.7, copies of which you have enclosed.

The answer is no. Under paragraph S5.5.5, the vehicular hazard warning signal operating unit is required to operate independently of the ignition switch, but no other lamp is required by the standard to do so.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:108 d:3/5/92

ID: nht87-1.37

TYPE: INTERPRETATION-NHTSA

DATE: 02/20/87

FROM: AUTHOR UNAVAILABLE; SIGNATURE UNAVAILABLE; NHTSA

TO: Robin Tallon

TITLE: FMVSA INTERPRETATION

TEXT:

The Honorable Robin Tallon U.S. House of Representatives Washington, DC 20515

Dear Mr. Tallon:

Thank you for your letter enclosing correspondence from your constituent Mr. George Seaborn of the South Carolina Association of School Superintendents, concerning Federal regulations for school buses. Your letter has been referred to my office for reply , since the National Highway Traffic Safety Administration is responsible for Federal programs relating to school bus safety.

In his letter to you, Mr. Seaborn expresses his concern about a Federal regulation that "excludes the use of vans capable of transporting more than 10 persons from use by schools." Mr. Seaborn explains that it would be difficult for school districts to c omply with a restriction on van use since large vans are extensively used for pupil transportation. He believes that schools should be permitted to use vans since those vehicles are safe for transporting passengers other than school children.

I appreciate this opportunity to clarify our school bus regulations. As explained below, there is no Federal prohibition directed against schools or school districts which restricts them from using vans carrying 11 or more persons. Federal law does, howe ver, affect the sale of buses to schools. NHTSA has the authority, under the National Traffic and Motor Vehicle Safety Act, to regulate the manufacture and sale of new motor vehicles. In 1974, Congress enacted the Schoolbus and Motor Vehicle Safety Amend ments to direct NHTSA to issue motor vehicle safety standards on specific aspects of school bus safety and apply those standards to all "school buses." The school bus standards we issued became effective April 1, 1977, and apply to each school bus manufa ctured on or after that date.

The parties subject to the Vehicle Safety Act are the manufacturers and sellers of new school buses. The Vehicle Safety Act requires each person selling a new "school bus" to ensure that the bus complies with our school bus safety standards. Under Federa l law, a van designed for 11 or more persons (driver included) is a "bus," and is a "school bus" if intended for transporting students to and from school or related events.

A person may sell a new bus (including a van designed to carry 11 or more persons) to a school or school district provided that the vehicle meets our motor vehicle safety standards for school buses.

Because our regulations apply only to the manufacture and sale of new motor vehicles, we do not prohibit school districts from using their large vans to transport school children even when the vehicles do not meet Federal school bus safety standards. Mat ters relating to motor vehicle use are determined by state law. However, in the event a South Carolina school district decides to buy a new school bus, we would like the district to keep in mind that the seller would be obligated under the Vehicle Safety Act to sell complying school buses. The seller should know that he or she risks substantial penalties if a noncomplying bus is sold as a school bus.

Since Mr. Seaborn is interested in transporting students in vans, I would like to clarify a few additional matters concerning our school bus regulations. In his letter to you, your constituent expresses a belief that large vans (i.e., buses) should be sa fe for school children since they are safe for other passengers. The legislative history of the Schoolbus amendments of 1974 indicate that Congress believed the need to protect school children who use school bus transportation is paramount. Large van bus es meeting our school bus safety Standards provide more safety features than other buses. School buses must meet stringent performance requirements, including those for interior protection, fuel systems, emergency exits, windows and windshields and seati ng systems.

New vans carrying 11 or more persons, conforming to our school bus standards, may be sold to school districts to transport their pupils to school related events. School districts may also purchase 9-passenger vans for school transportation, because such vans are considered "multipurpose passenger vehicles" (MPV's) and not "buses" or "school buses" under Federal law. We do not prohibit the sale of MPV's to carry school children nor do we require them to comply with Federal school bus safety standards. In stead, they must meet the performance requirements set by the safety standards for MPV's, which also provide high levels of passenger safety.

I hope this information is helpful. Please contact my office if we can be of further assistance.

Sincerely,

Erika Z. Jones Chief Counsel

Ms. Anne Graham Assistant Secretary for Legislation and Public Affairs 100 Maryland Avenue S.W. Room 3153 Washington. D.C. 20202

Dear Ms. Graham:

Enclosed, please find a copy of a letter from George Seaborn, President of the South Carolina Association of School Superintendents. regarding the prohibitive specifications for school vans.

I would appreciate your assistance in bringing me up to date on this matter, and the concerns expressed by Mr. Seaborn. as soon as possible.

Thank you for your consideration.

With best regards. I am

Sincerely,

ROBIN TALLON Member of Congress

RT/ma

Congressman Robin Tallon 432 Cannon House Office Building Washington, DC 20515

Dear Congressman Tallon:

You will see from the enclosed material that in 1977, the Department of National Highway Safety adopted a standard which excludes the use of vans capable of transporting more than ten persons from use by schools. None of the administrators in South Carol ina were aware of this legislation until recently. I am sure that you know that there are hundreds of these vans being operated by South Carolina school districts and many thousands more by school districts across our land. We have three in our school di strict which belong to the state and are furnished to us for the purpose of transporting children to our child development program. We also have our own vans which are used to transport small groups such as golf team, cheerleaders, etc.

All of these vans were legally purchased on the open market in South Carolina. It seems to me that if these vehicles are unsafe to transport youngsters then they are unsafe to transport any citizens in our nation. On the other hand, if they are considere d safe to transport citizens in this country who are not school students, they should be safe to transport school students. This regulation implies that certain classes of our citizens are entitled to higher safety standards than other classes.

I have been asked by my colleagues throughout the state to urge your immediate attention to this matter as all it is doing at the present time is creating additional liability for our schools systems. There is no way I can tell the parents for instance i n our child development program that we can no longer transport their children to their child development classes. I respectfully await your prompt action concerning this matter.

Sincerely,

George W. Seaborn, President South Carolina Association of School Superintendents