Mobility Transportation Services

Document ID: DOT-OST-2012-0147-0007
Document Type: Public Submission
Agency: Department Of Transportation
Received Date: October 01 2012, at 12:00 AM Eastern Daylight Time
Date Posted: October 4 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: September 6 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: November 5 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 1jw-815y-654l
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This is comment on Proposed Rule

Disadvantaged Business Enterprise: Program Implementation Modifications

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In regards to the request for comment regarding if those altering or modifying complete vehicles should be included as a TVM. Companies like mine modify complete vehicles to better suit public transportation needs. There are many differences between us and a bus manufacturer, such as: a) We modify vehicles that are already completed and driveable vehicles. b) We do not modify a incomplete chassis into complete vehicles. c) We are small companies ourselves. Most less than 25 employees. d) These modifications do not afford the same opportunities to use DBE suppliers as bus or other manufacturing. I support new language that exempts van modifiers and convertors who modify complete vehicles and do not modify an incomplete chassis. Another path could be to exempt companies that are under a determined employee threshold. Thank you for the opportunity to comment. Sincerely, Dave Brown, President Mobility Transportation Services