Interpretation ID: 20146.drn

Dr. Barbara Goodman
Director, Pupil Transportation
Commonwealth of Virginia
Department of Education
P.O. Box 2120
Richmond, VA 23218-2120

Dear Dr. Goodman:

This responds to your request for an interpretation on the continuing validity of the National Highway Traffic Safety Administration's interpretation letter of August 11,1987, to Mr. Ernest Farmer, Director of Pupil Transportation of the Tennessee Department of Education on refurbishing school buses.

This letter confirms that the August 11, 1987, interpretation letter to Mr. Farmer is still valid. For your information, I am enclosing a copy of a May 2, 1988, interpretation letter to Robert R. Keatinge, Esq. The Keatinge letter clarifies the Farmer letter by explaining that in interpreting 49 CFR 571.7(e), the Farmer letter understood the bus bodies involved to be new. Therefore, the Farmer letter did not purport to address the question of combining an old bus body with new and/or used chassis components.

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

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:VSA#571.3
d.7/16/99