This page has been updated with the Eugene School District 4J Transportation Department response to ABA's letter.
Dear Mr. McMahon,
On behalf of the oldest, largest and most respected association representing the motorcoach, travel and tourism industry, I wish to express my disappointment with your article, "Oregon District Shuns Motorcoaches, Runs ‘Yellow Charters’", and the myriad of errors and mischaracterization it contains, and take this opportunity to correct the record. This article in no way states the facts about the safety or reliability of the motorcoach industry versus the school bus industry. To say the motorcoach industry is unsafe is outright slanderous. In fact, the motorcoach industry is actually the safest mode of surface transportation according to both the U.S. Department of Transportation and the National Transportation Safety Board.
After reading your article, a number of safety questions come to mind regarding the Eugene School District's use of refurbished school buses.
I would ask if by altering these school buses, did the school district follow protocol and federal regulations to assure these buses were declared safe. Once the school district altered the bus to carry school groups who pay for the use of the bus, it became a charter bus and therefore now falls under the regulations of the Federal Motor Carrier Safety Administration, which has specific insurance requirements and compliance reviews of the bus fleet. One of which would include the regulations that for anything newly manufactured after 2016, 3-point seatbelts must be at each designated seating position. The buses would also require DOT numbers. I point out FMVSS 208, 209, 210, 213, 216, 217, 220, 222 as a few regulations that are very specific to the passenger safety features described.
School buses are designed for compartmentalization and have specific requirements for the height, width, curvature, the contactable surface, etc. Do these new seats meet those standards? When Mr. Ellison mentioned putting in luggage racks, school buses have a roof crush standard (216) and roll over standard (220), how are the bins in compliance with those? Were these "school buses" crash tested with all the alterations done to them?
In terms of total crash incidents, the truth is that school buses have more fatal collisions (98 vs. 32 in 2015) and more people die in those events (107 vs. 40 in 2015) than motorcoaches. Also to compare motorcoach accidents, where they operate on high-speed, high-density interstate highways, is unfair because most school buses generally operate in a low-speed intracity and neighborhood settings. The type of operation for “yellow charters” will make it more similar to motorcoach functions, than school bus and be in a higher risk environment as evidenced by already having a serious accident in less than 60,000 operational miles. In looking at data from federal safety regulators, motorcoaches have significantly lower rate of violations during inspections despite receiving more than 8 times as many inspections annually. While our historically low out-of-service numbers may also be related to other factors, they reflect the industry leading compliance and preventative maintenance programs put in place by reputable motorcoach operators with support from our manufacturers as well as the investment and dedication they make to continuing education and professional safety groups like the Bus Industry Safety Council and the Bus Maintenance and Repair Council.
So while many school districts may consider privatizing to save money, the real question is whether by creating their own buses, is the Eugene School District truly providing a safer trip than riding in certified motorcoaches with experienced professionally licensed drivers.
Your reckless article has done a great disservice not only to the motorcoach industry, but to the traveling public. I hope this letter can, at a minimum, mitigate the damage resulting from your article.
Sincerely,
Peter J. Pantuso
President & CEO
American Bus Association
June 14, 2017
RE: Response from American Bus Association to Thomas McMahon, School Bus Fleet; “Oregon District Shuns Motorcoaches, Runs “Yellow Charters’”
Dear Mr. Pantuso,
I appreciate your response to Thomas McMahon’s article featured in the June 2017 issue of School Bus Fleet magazine, “Oregon District Shuns Motorcoaches, Runs “Yellow Charters’”. However, there are many inaccuracies in your response and I must take this opportunity to clarify these inaccuracies to be sure readers and other industry professionals are fully and accurately informed.
These “refurbished” buses that you speak of are, in fact, not refurbished. Nowhere in the article does it state that I took an existing bus and refurbished it with updated charter-style equipment. These buses were purpose-built at the factory by the manufacturer. In fact, all three major school bus manufacturers (Blue Bird, Thomas Built, and International) offer this “upfit” for their customers. This is no different than ordering leather for your seats. It is simply an option that has been vetted through rigorous federally-mandated safety testing.
As one of the most federally-regulated vehicles on the road, all equipment installed on school buses must pass FMVSS standards. If it does not, it simply cannot be installed and used.
You mention that school bus seats are designed for compartmentalization. You are correct. With these charter-style activity seats, they still provide compartmentalization, as they do not recline. Reclining seats are not allowed on school buses due to the loss of this compartmentalization. Again, these seats meet all FMVSS regulations.
Seatbelts are currently a hot national topic in the pupil transportation industry. The fact is that unless local or state administrative rule require three-point lap/shoulder belts, they are not federally required on large school buses. My personal opinion is that it is a matter of time before all school buses are required to have three-point lap/shoulder belts, as more states are writing this requirement into rule. Oregon currently does not have this requirement.
You mention the addition of interior luggage racks and infer that this addition may compromise the roof/rollover crush standard. This again is false as interior luggage racks have no relation to the roof/rollover crush standard on school buses. Interior luggage racks are allowed in many forms on school buses. However, Oregon’s minimum school bus construction standards state that these must be enclosed, padded, and wrapped in fire-block vinyl.
In your response, you stated, “In fact, the motorcoach industry is actually the safest mode of surface transportation according to both the U.S. Department of Transportation and the National Transportation Safety Board.” We know that school buses and motor coaches are far safer than other means of student transportation, such as smaller passenger vehicles. Although on average about five school bus passengers die in crashes each year, school buses remain far safer than smaller passenger vehicles, especially those operated by teen drivers, which are 70 times less safe than school buses in terms of fatalities. Comparing school bus safety and motorcoach safety, however, is misleading at best. The operating environments and conditions of the two modes are often quite different, and serious injuries and fatalities to passengers are rare, making statistically valid conclusions about the relative safety of the two modes impossible. For those reasons, I would be interested in seeing any USDOT or NTSB studies, of which I am unaware, comparing the level of safety of school buses and motorcoaches.
Lastly, you mention that these “yellow charters” now fall under the purview and regulations of the Federal Motor Carrier Safety Administration (FMCSA) due to our school groups who pay for the use of these buses. This is incorrect, as we are governed and regulated by the Oregon Department of Education. We are a public agency and do not operate “for hire”. These buses are for internal use and are not applicable to FMCSA/DOT regulations.
I appreciate you taking the time to read this and allowing me to correct and clarify the issues you raised with ABA’s response to Mr. McMahon.
Sincerely,
Chris Ellison
Transportation Manager
Eugene School District 4J
ellison@4j.lane.edu