**Todd Busses, Inc.**

**166 Main St., P.O. Box 305, Eldred, Pa. 16731**

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> July 28, 2008

**Subject**: **Docket No. FTA-2008-0015, Notice of Proposed Policy
Statement on FTA\'s School Bus Operations     Regulations**

**Todd Busses, Inc.** contracts for the Otto- Eldred School District,
located in Duke Center, Pa., Mckean County. We contract 6 School Busses
and 10 School Vans; the school system has approximately 700 students. 
Our business has been operating since 1949. 

Todd Busses, Inc. fully supports FTA's proposal to clarify and reassert
its interpretation of the regulation on school bus operations at 49 CFR
605 for the following reasons.

-   Congress was clear in its purpose when it passed the prohibition on
    school bus operations by federally-funded public transportation
    operators: funds intended for the provision of public transportation
    must not be used to compete with private school bus companies. FTA's
    proposed Policy Statement is a reasonable and balanced effort to
    implement Congress's intent.

-   Transit operators that design and operate routes specifically for
    students, without regard to demand from the general public, are
    misusing federal transit grants. By its nature, school
    transportation operates during peak commuter hours---times when
    transit buses should be fully utilized by the general public. Buses
    used for school routes, then, cannot be "excess capacity," but must
    be purchased specifically for transporting students---a clear
    violation of FTA's regulations and a misuse of the funds Congress
    intends for public transportation.

-   Requiring transit grantees to operate within the boundaries of the
    regulation as interpreted by FTA in their Proposed Statement will
    not leave students stranded. The regulation and the underlying
    statutes provide an exemption for transit agencies where there is no
    willing and able private school bus operator. If school bus
    companies are not available or interested in the work, the transit
    operator can legally continue school bus service.

-   Students who are transported to and from school on transit buses
    rather than school buses lose the important safety protections built
    into school buses. Transit buses lack the structural integrity, the
    occupant protection features, and the traffic control devices of
    school buses. The National Highway Traffic Safety Administration has
    the responsibility to ensure that our children travel to and from
    school safely; and that agency, along with the National
    Transportation Safety Board, has said that all children should be
    transported in vehicles that meet the federal motor vehicle safety
    standards for school buses. Transit buses do not meet those
    standards. In addition, school buses provide a closed system with
    drivers trained to protect their passengers---very different from
    the open environment of transit, where children may be exposed to
    any number of unknown influences.

-   School bus service is more cost-efficient than transit. Even though
    the charge to school districts may be lower because of the federal
    subsidies enjoyed by transit agencies, the cost to taxpayers is
    higher. School bus service operates at about one-third the cost of
    transit service, and is about 40% more fuel-efficient.