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FAQ (Frequently Asked Questions) on Bus Testing

These FAQs do not have the force and effect of law and are not meant to bind the public in any way. This page is intended only to provide clarity to the public regarding existing requirements under the law or agency policies. Recipients and subrecipients should refer to FTA’s statutes and regulations for applicable Bus Testing requirements.
What is the process to submit a bus for testing, and did it change due to the Pass/Fail rule?

The process is described on the Bus Testing Requirements Determination and Testing Authorization Process page. Please review that page, as FTA has made several changes to the process due to both the Pass/Fail rule published in 2016 and recent process streamlining. 

The new and clarified administrative procedures and requirements for manufacturers during bus check-in in the “Pass/Fail” Bus Testing Final Rule became effective on October 31, 2016. These include but are not limited to: 

  • Demonstrating compliance with Federal Motor Vehicle Safety Standards (FMVSS) and several other National Highway Transportation Safety Administration (NHTSA) standards.
  • Submission of DBE participation goals.
  • Identification of maximum standee capacity on a prominent placard.
  • Identification of the manufacturing point of origin for major components.
  • Receiving authorization from FTA prior to the scheduling of full and partial bus tests at the Bus Testing Center. 
Are pre-“Pass/Fail” Bus Testing Reports still valid?   Generally, yes. If a bus model has not had major changes since it was tested, then its Bus Testing Report remains valid for that model.
How and when does Pass/Fail apply to new full tests?

Buses that completed testing or that were under contract for testing prior to the October 31, 2016 effective date of the current Bus Testing Regulation (49 CFR Part 665) are subject to the old requirements and will not receive a score or Pass/Fail rating, even if testing continued past October 31, 2016.

Testing contracts for full testing on new bus models signed on or after October 31, 2016 are conducted under the new procedures, and that bus model will receive a score and a Pass or Fail rating.    

How and when does Pass/Fail apply to new partial tests?

If the baseline bus model was tested prior to the Pass/Fail regulation and did not receive a score and a Pass/Fail rating, then the partial test of the variant of that bus model is not required to obtain a score, and the partial testing report will be issued without including a score.

If the baseline bus model was tested under the Pass/Fail regulation and received a score and a Pass/Fail rating, then the partial test of the variant of that bus model will receive a score for each of the newly-performed tests. The scores for the newly-performed partial tests will replace the corresponding scores from the baseline test, and a new overall score and Pass/Fail rating will be assigned to the modified bus model (the originally-tested configuration will retain its previous score and rating).

Can a bus fail a partial test? Yes. If a bus contracted for partial testing on or after October 31, 2016 does not achieve a passing score on any of the required partial tests, then it will be ineligible to receive a passing Partial Testing score on the new configuration. This would result in a failing partial testing report on the new configuration, except that the manufacturer will probably elect to withdraw the bus from testing prior to publication of the partial testing report. The baseline full Bus Testing Report would remain valid for FTA-funded procurements of the original configuration.
Will FTA go back and “score” existing Bus Testing Reports? No, FTA will not score Bus Testing Reports issued prior to the Pass/Fail regulation. 
Does a recipient need to acquire the highest-scoring bus?  No, FTA does not require recipients to acquire the highest-scoring bus.  Recipients may choose to make the score one of their evaluation criteria.
Can a manufacturer withdraw a bus from testing before the Bus Testing Report is published?  What happens then? Yes. Per the Bus Testing Regulation (paraphrased and in a different order):  
  • A bus can be withdrawn (for any reason) before testing is completed (§ 665.23(b)).
  • A Bus Testing Report will only be created following completion of the contracted full or partial testing (§ 665.13(b)).
  • If the bus manufacturer declines to release the report, or if the bus did not achieve a passing test score, the vehicle will be ineligible for FTA financial assistance (§ 665.13(b)).
  • The test report will be available to recipients only after both the bus manufacturer and FTA have approved it for release (§ 665.13(b)). Therefore, in order to have a Bus Testing Report published with a “FAIL” rating, a manufacturer would have to (1) decline to withdraw the bus from testing AND (2) decline to notify the Bus Testing operator that the manufacturer wished to prevent release the associated Bus Testing Report.
  • The operator will not make public any information connected to a bus test other than that included in a published Bus Testing Report (§ 665.13(f)). 
What happens if a bus fails its test? If a bus fails its test, that model will be ineligible for FTA-funded procurements, however there are remedies available to manufacturers during testing. If a failure occurs during testing, the operator will work with the manufacturer to identify the cause of the failure. The operator (and FTA, if requested by the operator) will review the adequacy of the corrective actions taken by the manufacturer and decide whether the affected tests may continue with the corrected configuration or must be restarted from the beginning or some other appropriate point. If the failure does not recur during the remainder of testing, that failure may be considered “corrected.”  The manufacturer also has the option to withdraw the bus from testing prior to publication of the Bus Testing Report.
How many/which buses have failed testing? Because § 665.13 allows a manufacturer to decline to release a Bus Testing Report, and a manufacturer may withdraw a bus from testing prior to report publication, FTA does not anticipate that a Bus Testing Report will ever be published with a “Fail” rating. A small number of bus models have been withdrawn from testing both before and after Pass/Fail, but § 665.13(f) bars FTA from discussing those.
What are the formatting requirements for the standee placard (ref. § 665.11(a)(3)?

The standee number placard must have 2-inch tall (or greater) characters in a font clearly readable from both the driver’s and the passenger area of the bus (text may be smaller but must remain readable). Production buses must also include the placard indicating the same or lower number of maximum standees.  

For a fixed number of seats, increasing the placarded maximum number of standees will generally require additional testing, so manufacturers are encouraged to test their buses at the highest permissible standee capacity.
 

Can a transit agency or bus manufacturer calculate the score that would have been assigned to a previously-tested bus? 

The FTA does not endorse self-scoring of existing Bus Testing Reports that were generated prior to the effective date of the Pass/Fail Final Rule. Some of the tests currently required were not required when older tests were performed, and there is no way for FTA to monitor the assumptions used or to perform quality control. Additionally, FTA believes that it would not be fair to go back and assess pre-Pass/Fail tests because manufacturers may have responded to failures differently in the absence of scoring and the Pass/Fail standard. 

Transit agencies remain free to develop evaluation criteria for their own internal use. 
 

How does the new Bus Testing Regulation apply to remanufactured buses?

The Bus Testing Regulation does not currently apply to remanufactured buses, except that the original vehicle must have met Bus Testing requirements at its time of acquisition by the original owner.  

FTA Circular C5010.1E, “Award Management Requirements,” provides additional information on FTA’s current policies regarding remanufactured vehicles. The circular defines a Remanufactured Vehicle as, “a vehicle that has undergone substantial structural, mechanical, or electrical rebuilding, restoration, or updating by a third party and then is sold or leased to a transit agency.”  
 

Is Bus Testing required if a grantee rebuilds or modifies vehicles in its existing fleet? No.  49 U.S.C. 5318 only requires testing of new bus models.
Did the “Pass/Fail” rule change any Bus Testing procedures?

Yes.  

The Shakedown test has been eliminated because it’s redundant with the Structural Durability test, and historically no buses have experienced severe permanent deformation from the Shakedown test.  

Fuel Economy (Energy Efficiency and Range for battery-powered vehicles) is now measured on the dynamometer using realistic transit industry driving cycles instead of on the test track, and is performed simultaneously with the Emissions test (if applicable). This change has increased accuracy, relevance, and cost-effectiveness of the Fuel Economy test. 

Interior Noise is now measured in two additional operating conditions – while operating on the durability track and while operating on a public roadway. Both of these added tests are informational only and are not counted toward the Pass/Fail score.
 

How much ballast weight is used for seated, standing, and wheelchair passengers? Although there was significant discussion of the passenger weight assumptions during the NPRM comment period, the final rule made no changes in these assumptions. Buses will continue to be ballasted with 150 pounds for each seat and each manufacturer-rated standee, and 600 pounds for each wheelchair position
How does FTA’s §5312(h) Low and No-Emission Component Assessment Program (LoNo-CAP) relate to the Bus Testing Program? LoNo-CAP complements the §5318 Bus Testing Program, but they are separate programs with some key differences.
  • §5318 Bus Testing is required as a condition of FTA grant eligibility.  LoNo-CAP is voluntary.
  • §5318 Bus Testing tests a complete bus model as an integrated system.  LoNo-CAP tests individual components that could be integrated into various low or no-emission (LoNo) bus models by any manufacturer.
  • §5318 Bus Testing will generate performance-based scores and Pass/Fail ratings for buses.  LoNo-CAP will only provide performance data.
  • LoNo-CAP will be conducted at different locations than Altoona.
  • A manufacturer submitting a bus for §5318 Bus Testing is responsible for 20% of the testing fee.  A manufacturer submitting a LoNo component for LoNo-CAP testing is responsible for 50% of the component testing fee.
Are the first five units of a new bus model automatically exempted from Bus Testing?

No. In general, a new bus model must complete Altoona testing and receive a passing score before the first unit of that bus model is eligible for FTA grant funding.  

When introducing a new bus model with major new technologies or design features, a manufacturer can request a Prototype Waiver that may allow for up to five units of that major new design to be sold to FTA grantees prior to testing of the final production design. Prototype Waivers are NOT automatic, and the bar for obtaining a prototype waiver is high. See the Prototype Vehicle Policy for details.  
 

Can a grantee contract to acquire a bus model that hasn’t completed Bus Testing? Yes, however this exposes the grantee to significant risk if the bus performs marginally when tested, is delayed in starting or completing testing, and/or does not receive a passing score. The authorizing legislation for the Bus Testing Program, 49 U.S.C. § 5318, does not prohibit recipients of FTA funds from soliciting and awarding orders for buses prior to the completion of testing.  Bus purchasers may release non-FTA funds for buses at any time permitted by their own state and local regulations, as the transfer of those funds is not prohibited by Federal statute. The purchaser remains responsible, however, for ensuring that the vehicle complies with all FTA requirements upon final acceptance in order to maintain eligibility for FTA funding.
When is the Emissions test required?

The Emissions test is always included in full testing of new models (except zero-emission buses) because this data is required to generate scores and pass/fail ratings.

The FTA will make case-by-case determinations for buses subject to partial testing because of major changes made since the bus was previously tested. The primary consideration is whether FTA would expect to obtain significantly different data from that obtained in previous FTA Bus Testing.
 

Can a manufacturer use the Bus Testing Facility to conduct supplemental and/or confidential testing? Yes, at the discretion of the Bus Testing Center, which will prioritize official Bus Testing activities. The 80% FTA subsidy of the testing cost is only available for official FTA Bus Testing. Contact the Bus Testing Center for details.
Do vans (with or without ADA equipment) need to be tested?

It depends.

Section 665.5 defines an “Unmodified mass-produced van” as “a van that is mass-produced, complete and fully assembled as provided by an OEM. This shall include vans with raised roofs, and/or wheelchair lifts, or ramps that are installed by the OEM or by a party other than the OEM provided that the installation of these components is completed in strict conformance with the OEM modification guidelines.”

The Testing Guidelines page says “unmodified mass-produced vans are exempted from testing in the 4-year, 100,000-mile service life category.  Unmodified mass-produced vans offered in the 5-year, 150,000-mile (or higher) service life category are subject to testing.”
 

If a vehicle has been tested and 1) the manufacturer subsequently changes the vehicle’s model name, or 2) if a different manufacturer subsequently acquires the rights to build that bus model, would the vehicle need to be retested, or would the original Bus Testing Report(s) suffice?

Bus Testing Reports apply to a bus model. If a bus design along with its manufacturing drawings, tooling, jigs, etc. is renamed, or is transferred to another manufacturer who builds the same vehicle using the same design, materials, and methods, then FTA generally wouldn’t expect to obtain significantly different data from re-testing the vehicle and the original Bus Testing Report would generally suffice. If FTA has doubts about whether the (new) manufacturer is truly building the same design using the same materials and techniques, we might determine that additional testing is required.  

Note that 49 CFR § 665.7(b) says, “. . . the recipient [of FTA grant funds] shall be responsible for determining whether a vehicle to be acquired requires full testing or partial testing or has already satisfied the requirements of this part.” Therefore, if a recipient questions the applicability of a Bus Testing Report because the manufacturer name on the report is different than the manufacturer of the vehicle, then that recipient could decide that that Bus Testing Report was not sufficient for the bus model in question.  

When a chassis OEM makes a major change(s) to that chassis, are each of the affected bus manufacturers required to submit request(s) for an FTA determination(s) on the impact of the chassis change(s) on testing requirements for previously-tested bus model(s)? In many (although not necessarily all) cases, a major change to a chassis could produce similar new data on all bus models built on the related OEM chassis.  In such cases, an industry group/organization could approach FTA to request a generalized determination on behalf of all affected bus manufacturers. The FTA would respond to the requesting entity, which could then share FTA’s response with its members. The FTA could also post a Program-Wide Determination on the Bus Testing Website. An example of this type of industry association is the Mid-Size Bus Manufacturers’ Association (MSBMA), which has offered to coordinate such cross-cutting inquiries on behalf of its members.  
What if my question isn’t answered here? Send your question to the FTA Bus Testing Program Manager. If your question is related to a specific situation or product, you’ll probably receive a private response. If your question applies to the bus industry more generally, it may be answered on the Program-Wide Determinations page, or on this FAQ page. 

 

Last updated: Tuesday, June 1, 2021