Anthony Nokes - Comment

February, 24 2010 DOT Docket Management Facility, M-30 U.S. Department of Transportation West Building, Rm. W12-140 1200 New Jersey Ave, S.E. Washington, D.C. 20590 Re: Docket No. NHTSA-2009-0190 RIN: 2127-AK20; NPRM FMVSS 217 Bus Emergency Exits and Window Retention and Release Thomas Built Buses, Inc. a division of Daimler Trucks North America LLC wishes to provide the following comments regarding NHTSA’s Notice of proposed rulemaking (NPRM) to Federal Motor Vehicle Safety Standard No. 217; Bus emergency exits and window retention and release. In support of the School Bus Manufacturers Technical Council docket submission of January, 29 2010 we offer the follow comments: Location of Exterior Release on Rear Emergency Exit Door; ref. FMVSS 217. S5.3.3.1(a) NHTSA requested comment on whether they should require the exterior release to be no further than two inches away from the edge of the door. Thomas Built Buses agrees with the agency to amend FMVSS 217 to specify that the exterior release (handle) for school bus rear emergency exit doors may be located near the edge of the door on the side opposite the hinges. We request that NHTSA does NOT specify or require the exterior release (handle) be positioned by an arbitrary edge dimension. We request that the edge dimension be determined by the individual manufacturer design parameters. This would give the manufacturers some tolerance and flexibility in their respective designs. Thank you for your consideration in this matter. Daimler Trucks North America Anthony E Nokes Senior Development Engineer Compliance and Regulatory Affairs