./ ,0·us, DepoJ'tn'lentof TrcflsportaffonFederal ifaNitAdmirn;fration

4QO S. ••• 'dhSt. S.w.WashingtOn, D.C. 20590

Mr'•. Rick McMullenCoa~h and Equ~pmentP_O. Box 35· . .BroWn St.. ~tension"Penn yan,q. NY 14527 '.

Dea:c' 'Mr .: McMullan

This"is.iIi .response to your latter in ~hiCh you requested theFederal 'J,:'rcmsit AOm;nistration (FTA) to' aetexmine whether' theGuardian and·SRW.~hoenix models' fall ~ithin the same fQmilY'of

. 'li:ehicles as ·the previously tested D~ phoe;rix model a

., .. ." -- - . -'~-

Rs'U'ieW'of your ~Gtter, drawings, azld <lata submiuted shows thefollowing illfo:rma.tion: ... ..

o . ''l'he DRW.Phoenix 'mQdel that completed testing at PTI inJanuary J.g9S ·.(Report !qo •. l?'l'r-~~-R.94~6-0·1) was. bu:il.t on a

'. dual rear wheel Ford.E-150 co.tnl1lel:"cial· 'cutaway ehass1swith a.176-inchWheel~seQ..~ 0·. The proposed 'SRW.~hoanix. is bu-iJ.t on' a si.n.gle rear wheel

Ford 5-35'0 Gommel::Cial. cut:.away cbassis wi-ch'an 13S";'inchwhee.lbase.. '. .

. '" The prQPosed Guaxdian model is built: from. a. F.orclEconoline E-350 conversion vane '.. '

. . .The Federal Regi::;te:t." dated November :3, 1953, 'established four

, '.subcategories fo.. the t.esting of 5- ana 4-year service ~ife SIZli!tllbuses: u.nmodified mass-produced vans, Unmodified. mass-producedchassis I .,.ehic~e.s·ma.Jl.u£a.ctured from modi·:Eied mass"'produced chas.sie

,.or'vansg and veh~cles manufactured from non mass-produced chassisor vans Q •••• -- _ •••••••••• - •

..For purpose5 Qf p~rtial testing of buses in·the 5- and 4-year bustesting eategor~~s, we 'e£~ablished the conoep~'of a £~ly o£' .vehicles. T~is'concept includes, -all'bus models tbat are.producegby a small bus manufacturer tbae are built us.ingunmodifiad mass-produced. chassis (second su.bcateQ"o1;y}'·'·su.ppl:iad byone or more original equipment. manu.facturers (OD:{)'•• __ including .the various cha.ssis ~e~lbases chat:. are supp11e<1by t:he OEMs_-The S&W.and DRW Phoenix models are boeh built. en an unmodi.fied·

2 =

mass-produced chassi~ manufactured by Ford Motor CqmpanYitherefore r f:l;ie&both fall into the same family of vehicles.

. .-. -. .

You·shou.ld be·aware" however, that::it is conceivable that:.morethan one member.of the family may be requ.ire~ t:o' undergo i:.esting

.at: ·l?TI~ This may be caused by differences ·.in the structuralconfiguration. from one famiJ.y m~ber to another that. wouJ.dbe~acted to produce test.resu~ts that are significantly differentfrom those previously obtained at P'I'I •.

!n the case of· the SRWPhoenix, ·we have: det.e:r:mined tha.t the te"s'C .resultsfo~ this model would be expected· to equ~ or surpasspl:ev~i:ous 'Cast :resuJ.ts ~th regard. to the .structural integrity,performance and safety chaxacterist.ic:s of 'i:he vehio~e_ Thus,additional testing will not be required of the SRW ~hoenix model. "

. - . .'

The ~uardian model vehicle·is b~sed· on Ford's Econoline B-3S0 ~~cG.o.ve;rsion van; -cherefore, it does not; 'fall wj:ehin the same family ~of vehicles as the SRWand DRW Phoenix model's - This vehicle falls 'into the modified mass-produced chassis or van catego~ since a.significant poxtion og the.vehic1e"s body section has beenrep.laced. vehicles in this catego%y, which is inc1.usive of your'Guardia;p. model.... are subjected. to ful.l. testing at PTI.

" ."If yau desire additional intor.mati·~4-~~~=,ao~n~o~ hesitate to":ea1.J. Ahdo S. 1tA'1100 of my staff at (202) ~, M.~Q.If'..}.\

\"-----~ --:::;:::.,.-=.::::=:==:;-:...-",, .,

. A. M.· .Tony YenDeputy "Associate Administrator. for"Technica~ Assistance, anaAct:.ing Director Po •• "

" Office of"Engineering. ..

co: Dave K1.inikowski " ".Penn~lvaniaTranspo~tationInstitute

~.U,S.~~

of Trcrsportaflon~TI'ClldA~trafIc>n

.'

Testing Requirement Guide~ines for.Five ...and Four Year Buses; andPartial Bus Testing Procedures fer AllBus Categories

Preporod by

8oez.AJi@n& Hamilton Inc.4330 EastWert HI~wavBethesda. MO 2J814 .

Pi'E!1Xlred fer

u.s, Deportment of Tra~cnFederal Transit Admlnil1Tatlon .Offtce ot·TochnlcOl Alllstance ~ct SClfetywOtt'!lngt~. D.C. 20590

. Final naportVnon 1.0

April 23 19113

.. B-1.- ,

t *_

Testing Requirem~nt G.uidelines·forFiv~ and Fo~-Year Buses,andPartial Bus Testing Procedures for All Bus Categories .

LiitSQ

Background

On May 25, 1989, the FTA published a notice of proposed rulemaking (NPRM)that established The Pennsylvania Transportation Institute (PTI) bus testing fadlity inAltoona, Pennsylvania, and 1I••.• provides that no funds Obligated by the FrA afterSeptember 30, 1989, under the Federal Transit Act ... may be used to purchase a 'new busmodel' unless a bus of such modelhasbeen tested at the facility:''' The NPRM proposed'testing all bus models used in mass transit. However, the FrA realized the testing -facility would not be able to handle all bus. categories as proposed. Therefore, the FTAincrementally implemented new and- redefined categories of buses for testing andissued modifications to coincide with the facUitys .readiness· for each vehicle category.

The FTA recently issued (under 49 CFR part ~) its revised Bus TestingProgram; Reinstatement and Modification of Interim Final Rulemaking (IRM), datedJuly 28p 1992. The IRM introduced the following major changes: ,

. '-e Two new bus categories, light-duty buses and modified vans, which are

now are subject to testing. These two categories include five-year (or150,000 mile minimum semce life) buses and. four-year (or lOO,D09mileminimum service life) buses •.With this addition, tb, FTA has included allcategories of buses that it.intended to cover under the original bus testing

. procedure N'PR¥. '. . .

e Partial testing" which permits less than full testing for buses beingproduced with major changes. p~ testing only applies for busespreviously tes~ at PTI. The lRM defines partial-tating as "theperfo~ce o~those b1l5 tests which may yield. significantly differentd~ta from that obtained in ~ous bus testml. conducted·at the bus

'.teSting fadlity.'fJ

Q Several new definitions, which were added or modified to be consistentWith the.above changes. . .

.Appendix A includes seled:~ excerpts from the July 28, 1992, IRM.

The purpose of thisdOC'Uinent is twofold. FIrSt, this document helps, .manufacturers underStand the definition and idea of a "family of vehicles." Second, itdelineates ~ting requirement guidelines and 'partial bus testmg procedures. Theinformation presented in thiS document shall apply to all categories of"vehides' asdefined in the'IRM; unless otherwise noted.

Page 153 . BTG.0623iJ.I.f

TESTING REQtnREMENl GUIDEUNES FOil FIVE..AND FOUR.YEARBUSES

Most of the vehicles built iff the newly defined five- and four-year bus categoriesuse mass produced chassis and vans. The similarity of these vehicles allows for the .definition pf several "families of vehicles". The following sections describe what

. constitutes a family of vehicles for both five- and four-year buses.

101 Vehicles Built Using Unmodified Mass Produced V~

Unmodified mass prOduced vans do not require any testing. An unmodifiedmass produced van is a van that has no changes other than those installed by theoriginal mass· produced van manufacturer. . .

. Mass produced vans with raised roofs, lifts, and Ior ramps, installed by a partyother than the original mass produced van manufactUrer, are considered to be vanswith no major changes for the purposes of the bus testing rule and will not be required.to undergo testing, if those installations are completed in strict confcrmance with theOriginal Equipment .Manufacturer's (OEM) modifica~c:»n guidelines. .

1.2 . Vehleles Built Using Unmodified Mus Prodl!ced 0Lusif;J .

All vehiclesp from each small bus manufacturer, built usingan unmodified· massproduced chassis are to be considered part of the same family. An unmodified massproduced chassis is a chassis whose structure remains unchanged; or is altered only instrict conformance with the OEM's modification guide~ines,except those vehicles withchanges covered by Section. 1.3. The family·of vehicles would include the various-wheelbases that are .supplied by a mass produced chassis manufacturer. These: vehiclesare part of the same family for that sm.dl bus manufactw.-er only.

Page 2if.

Certain changes to mass produced chassis or vans will cause a vehicle to falloutof the family of vehicles conceptas set forth in Section 1.2.' Such vehicles would beconsidered unique models for purposes of the bus testing rule. Examples of suchchanges include: .

a, Additionofa tandemor tagwe. b. Installation of a drop floorc. Changes to GVWR from OEM ratingd. Modifications not in compliance with the OEM's modification guidelines,

such as extensions to the chassis or a significant replacement of a vehiclebody section made by a party other than theeriginal manufacturer

1.41 Vehicles Built Using.Non·Mass Produced Chusis or ViAM

.' Vehicles built using non-mass produced chassis or vans retain their own modelidentity and are subject to full or partial testing procedures at PTI.

Page 3'"' . BTG.04Z393. iO