Bus Testing Requirements
Q. Does a cosmetic change in a bus require a retest at Altoona? We are in the process of designing a new exterior look for one of our buses. This will alter the front and rear fiberglass caps on the vehicle. The structure of the bus will not change, nor will the components. We believe that we do not have to re-test the bus, as the changes are merely cosmetic.
A. We forwarded your question to FTA, and this is their response:
Generally, cosmetic changes in the fiberglass trim on a bus, where that trim carries no significant structural loading or function, do not constitute major changes for the purposes of Bus Testing. While we have not of course reviewed the technical details of these changes, the description suggests that the proposed changes would not be major changes; consequently it's unlikely that additional testing would be required if we were to undertake a formal review and determination.
Q. Are there any procurement issues if the invitation to bid requires the bidder to submit a copy of the Altoona Bus Test Document with the bid rather than prior to the first vehicle being delivered? The information contained in the Altoona Bus Test document provides information that should be considered in the award of the vehicle contract.
A. FTA originally required the Altoona Test documentation to be submitted with the bids, thinking this would allow agencies the benefit of comparing bus performance data as part of the contract award decision. However, when bus manufacturers, who had not yet completed testing of potential new vehicles, refused to spend the funds to test those vehicles without assurance of a contract, competition was often lacking, and the FTA then moved the test documentation requirement back in the process to before acceptance of the first vehicle. We were told that FTA would have no issue with requiring the test documentation with the bids if adequate competition could be obtained using that procedure. If competition would not be adequate, however, and there were additional manufacturers who would bid if testing were delayed until after award, then FTA would not be in favor or requiring Altoona test data with the bids.
Q. Under Subpart B 665.11 Testing Requirements (5)(f) states that ....."the use of a bus model in a service application higher than it has been tested for may make the bus subject to the bus testing requirements".
Does this mean that even though a bus fits into the testing category of 4 year/ 100,000 mile by definition, If MDOT requires a minimum service life of 5 years/150,000 miles ... must the bus be tested in that category?
A. Bus manufacturers self-select which service life category they test their buses in. However, FTA funds may not be used to procure a bus in an application requiring a higher service life category than the highest service life category in which that bus has been tested. For example, if a bus has been tested in the 7-year category, it may be sold using FTA funds in the 7, 5, and 4-year categories, but it may not be sold using FTA funds in the 10 or 12-year service life categories.
Q. What are the duty-cycles under which the 4, 5 and 7-year buses must be tested at the Altoona facility?
I am aware of a duty-cycle (Design Operating Profile) for 10 and 12-year buses that is described in APTA's "Standard Bus Procurement Guidelines." I would like to include a description of the Design Operating Profile for a 5-year paratransit vehicle in the technical specifications I am preparing.
A. The intensity of the duty cycle used in Altoona testing is the same for all service life categories, only the duration of the testing changes. Buses tested in the 4, 5, 7, 10, and 12-year service life categories drive repeatedly over the same set of "obstacles" on the durability testing track, with the number of laps corresponding to the service life of the bus. The mileage accumulated on the durability test track for each service life category of bus is as follows:
|Service Life Category||Durability Track Mileage|
For a physical description of the test track, please see [no link provided].
Q. Molly Trolley has told us that their rear engine "Trolley" built on a Freightliner XB-55 chassis meets the Federal requirements for Altoona Testing at 10 years, 350,000 miles. However, the only information we can find is a listing on a Molly Trolley built on a Freightliner MB-55 front engine chassis which is at 12 years, 500,000. Does the testing done on the Freightliner MB-55 model qualify the XB55 model or does the unit require Altoona Testing to qualify under the Federal guidelines?
A. The Freightliner MB-55 chassis is a front-engine chassis, while the Freightliner XB-55 chassis is a rear-engine chassis. Trolleys built on these chassis are separate bus models, so test results from one would not apply to the other. The manufacturer would need to provide the potential grantee with a test report for the appropriate model.
Q. Our company is in the process of purchasing 100 plus small, wheel chair accessible, Paratransit vehicles possibly using Ford E-350 cutaway chassis and new power train. We would like to know if the Altoona vehicle testing requirements would need to be performed if engine and transmission change were made by an O.E.M.? Ford Motor Company is replacing their 7.3 diesel engine and 4R100, 4 speed auto overdrive transmission that have been used on their E-350 cutaway chassises up to their latest 2003 production run. For the 2004 E-350 cutaway chassis production, the engine and transmission option will change to a new 6.0 diesel engine and a new 5R110 auto overdrive transmission. This production change affects this type of chassis, and is due in part to product improvements that will influence environment and efficiency for 2004.
Your clarification on what constitutes a major component change will help in answering this type of question from potential bidders. As we understand the requirements in Part 665, Section 665.5, it looks like the manufacturers of Paratransit vehicles would need to perform an Altoona test on this new power train combo.
A. FTA's policy on testing requirements for small buses (we interpret this to mean buses in the 4-year, 100,000-mile and the 5-year, 150,000-mile service life categories) is that we generally allow manufacturers that have satisfied Altoona testing requirements with a bus built on one mass-produced chassis to switch to a similar Altoona-tested mass-produced chassis without requiring further testing.
Since the new 2004 Ford E-350 chassis with a 6.0 diesel engine and 5R110 auto overdrive transmission has not yet been Altoona tested, a bus built on that chassis would have to complete the Performance, Fuel Economy, and Noise tests at Altoona. After those tests are complete and the test report is publicly available, then this chassis, engine, and transmission combination could be used in buses built by any manufacturer that has satisfied testing requirements with a bus built on the older E-350, without triggering additional testing.
The above assumes that the chassis materials, construction techniques, and structural design are not substantially changed for the new 2004 version. If they are (we have not been asked to make a determination on this question), then Full Testing would be required. Once one bus model built on the 2004 chassis completes this testing, then additional testing would not be required for other bus models from that and other manufacturers built on the 2004 chassis, provided that their bus model had satisfied testing requirements when offered on the earlier chassis.
This policy does not apply to the 7-year, 200,000-mile and higher service life categories. Buses in these service life categories are considered distinct models even if built on similar chassis.
Q. How does the bus testing requirement apply to a first time purchase of hybrid electric/diesel busses?
A. The FTA "Dear Colleague" letter dated May 9, 1997, provides guidance on how the bus testing requirement applies to hybrid-electric buses. This letter states:
"As with other transit buses, hybrid-electric buses must conform with the applicable Federal Motor Vehicle Safety Standards, as well as other Federal, state, and local safety requirements. If acquisition of these vehicles involves the use of Federal funding, competitive procurement procedures must be employed and FTA bus testing requirements must be met. Furthermore, the bus testing prototype exemption only applies to the first five vehicles of a particular new hybrid electric bus model sold by a manufacturer to single or multiple grantees. Consequently, Federal bus testing requirements must be completed prior to final acceptance of the sixth and following new model buses, in which Federal assistance is used for their acquisition.
Q. I know that Altoona testing is required in order for a transit property to buy and operate buses funded by the FTA. However, somewhere I heard that orders for 5 buses or less are exempt from the testing requirement. I haven't found anything in the circular or best practices manual that either supports or refutes this. I haven't been able to find 49 CFR 665 to verify either. Can you tell me if there is an exemption for small fleets or am I mistaken?
A. The statute and regulations require that all new model buses be tested before Federal funds could be expended. Administratively, FTA divided the universe into two halves - production models and demonstration models. Because Congress, in it's report accompanying STURRA, did not want the testing requirement to stand in the way of new technologies, Steven Barsony, former FTA Director of Engineering, issued a memo exempting demonstration models from testing, and establishing that number as five or less. If a manufacturer sells models in excess of that number, whether to the purchaser of the initial five or to another, the testing requirement will apply to the 6th vehicle.
In addition to Mr. Barsony's memo, Former FTA Administrator Gordon Linton included the 5 vehicle prototype policy in a 1994 "Dear Colleague" Letter. The specifics of the prototype policy were explained in an attachment to the 1994 letter.
Q. We have a contract with NABI for supply of composite body buses. NABI wants to deliver these buses before completion of Altoona testing. Can we pay any amounts to NABI before Altoona testing is completed?
A. FTA's bus testing program is mandated by section 5324(c) of the Federal Transit Laws (49 U.S.C. Chapter 53) and was instituted by Congress in 1987 to address problems caused by vehicles that could not withstand the rigors of daily transit service. For this reason, Congress required that all new bus models be tested and a test report be provided to the purchaser before any Federal funds could be expended on that vehicle, giving the purchaser the opportunity to identify and correct potential problems with the vehicle prior to final acceptance.
FTA, however, has tried to remain sensitive to the needs of its grantees and the vehicle manufacturing industry by permitting recipients of FTA funds to solicit and award orders for vehicles prior to the completion of testing, and allowing purchasers to release state and local funds for the vehicles prior to delivery of the final test report, as the transfer of those funds is not prohibited by statute. The purchaser remains responsible, however, for ensuring that the vehicle complies with all Federal requirements upon final acceptance. If you have any questions, feel free to contact Mr. Marcel Belanger, FTA Bus Testing Program Manager, at (202) 366-0725.
Q. Is there an exception or waiver to Altoona testing in order that rural transit systems can purchase school buses using FTA funds to contract with head start programs to help with the matching portion of the Section 5311 program? Can the governor waive this requirement? Are there any suggestions on what could be done to allow the head start and rural transit programs to collaborate and support each other?
Federal mandates were issued last year regarding the transportation of head start children. By the year 2006, head start children must be transported in school buses or alternative vehicles that meet the same crashworthiness tests. We have even considered pooling funds to have a bus Altoona tested, but I am told that this is not a realistic option.
A. The bus testing regulation is a statutory requirement that is directly connected to the use of FTA funds to purchase a vehicle. In other words, if FTA funds are used, the vehicle must be tested. Unfortunately, there is no waiver provision available, either through DOT, FTA, or through a State's governor. I note, however, that many suitable school bus-type vehicles (particularly those in the 4-, 5-, and 7-year service life categories) have already completed testing at Altoona.
Feel free to call or email me if you have any additional questions.
Office of the Chief Counsel
Federal Transit Administration
Q. Where can I access the Dear Colleague Letter of 1994, which defines "prototypes" and that a grantee can accept up to five prototypes without completion of Altoona testing?
A. To obtain a copy of this 1994 Dear Colleague Letter, you can contact Mr. Marcel Belanger, FTA Bus Testing Manager, at 202-366-0725. Mr. Belanger can also help you with your bus testing questions.
Q. Is the FMVSS221 regulation relevant to the commercial transit bus industry? Or is it only for school bus application?
A. FMVSS (Federal Motor Vehicle Safety Standard) No. 221, School Bus Body Joint Strength, applies only to school buses, and is not a basis for testing public transit vehicles under FTA's Bus Testing program (see http://www.vss.psu.edu/btrc.htm). (Posted: May 2009).
Q. When new buses are purchased by transit properties, is the cost of final bus inspections covered by FTA? If so, how are they covered? Do the inspections fall under 5307 monies?
A. Because the resident inspector requirement is part of the Buy America post-delivery compliance requirements for rolling stock acquisitions (see 49 CFR Part 663, specifically in section 663.37(a)), the inspector cost can be included within the grant. We explicitly authorize such costs in section 663.11, and further elaborated on our rationale in our September 24, 1991 Final Rule (see http://www.fta.dot.gov/legislation_law/12316_575.html).
In addition, FTA (TPM) responded to this question previously (note the highlighted portions of the excerpts from Buck’s email below). Keep in mind that 49 USC 5302(1) was moved to 5302(3) by MAP-21, although the text in 2 CFR Part 225 remains the same. (Posted: October, 2013)