James J. Burns - Comments

Document ID: FTA-2011-0015-0002
Document Type: Public Submission
Agency: Federal Transit Administration
Received Date: April 19 2011, at 12:00 AM Eastern Daylight Time
Date Posted: April 21 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: March 14 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: May 13 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80c3078b
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This is comment on Rule

Bus Testing: Calculation of Average Passenger Weight and Test Vehicle Weight

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I am a small rural operator using body-on-chassis vehicles. I am concerned about this change for the following reasons: 1. Body-on chassis vehicles have already had the seating reduced to meet the GVWR requirements from the vendors. 2. Under the new guidelines, to maintain a bus at 18 passenger would require heavier frames and brakes. I question that this could be done for twenty-five hundred dollars 3. If we stay at our current passenger vehicle as it is now being built, we would have to decrease the capacity to 15, a sixteen percent drop in capacity. 4. It appears that no matter how it is presented, rural transit will be faced with a four to sixteen percent increase in costs without any way to recover.