Motorcoach Safety Plan

March 27, 2008 Dr. Roger Saul Director, Office of Crashworthiness National Highway Traffic Safety Administration 1200 New Jersey Avenue Washington DC Re: Motor Coach Safety Research; Docket NHTSA-2007-28793 Dear Dr. Saul: The undersigned motorcoach manufacturers and operator associations appreciate the opportunity to contribute to the ongoing research relating to motorcoach safety and the ability to discuss the direction and focus of the research. We remain committed to providing technical advice and expertise to the agency for developing a comprehensive and integrated motorcoach program to advance the safety of motorcoach operations. We are taking this opportunity to comment on the proposed protocols for roof crush and rollover testing for motorcoaches as inserted by your office into the above docket on January 16, 2008. There are several areas of concern. First, the vehicles to be tested, two 1991 MCI Model MC-12s, and two 1991 Prevost Le Mirages, are of such an age and outdated design generation that they are no longer representative of the current fleet of motorcoaches in operation. Consequently, we are concerned that using these outdated models in the roof strength and rollover crash test will produce results that might not provide a sufficient scientific foundation on which to base requirements for current and future motorcoach models. Second, we expect that the math data records for the above models, to the extent that they even exist, are not reasonably suitable for establishment of a correlation between their structural design and the results achieved by this proposed test program. This is a critical aspect, as achievement of correlation between detailed structural analysis on the one hand with the actual test results of the same coach model on the other hand would be essential to predict probable future structural performance outcome, as envisioned by the ECE approach. Third, we question whether using roof crush testing standards developed for school buses is appropriate to develop data for use in considering potential requirements for motorcoaches. There are substantial differences in the consumers? use expectations between school buses and over the road buses, such as visibility, comfort, aesthetic appearance, in-transit mobility of passengers with access to personal effects and on-board facilities, etc, each of which has considerable effect on the bus?s structural design. Thank you for your consideration of this request. Respectfully submitted, American Bus Association, Inc. International Motor Coach Group, Inc. Trailways Transportation System, Inc. United Motorcoach Association, Inc. Motor Coach Canada Motor Coach Industries International, Inc. Prevost Car (U.S.), Inc. Setra of North America, Inc.

Comments submitted on behalf of American Bus Association.