Test Determination Process
New bus models must complete the full set of test procedures in order to be acquired by recipients of FTA capital funds. If a previously-tested bus is subsequently built with changes in components or configuration, then a determination must be made as to whether the change(s) are major changes that will require additional partial or full testing for that bus model.
The Bus Testing Regulation states at 49 CFR Part 665.7(b) that, “It is the responsibility of the recipient in dealing with a manufacturer, to determine whether a vehicle to be acquired is subject to [the requirements of the Regulation].” In situations where a manufacturer or other entity is uncertain whether the change(s) to a bus model are major changes, they may request assistance from FTA in determining whether the proposed changes would require additional full or partial testing.
Manufacturers and recipients are encouraged, however, to review the information available on this website before requesting FTA assistance. This information is being provided in the hope that it may answer many questions without the delay inherent in requesting an official FTA determination, and also to foster consistency in the application of the Regulation. When in doubt, however, we recommend that the parties request an official determination.
Thus, recipients and manufacturers should generally follow this process to determine whether a modified bus model is subject to additional testing:
- Review the guidance provided on this website (check the page modification date and the Latest Updates page, as the information may be updated from time to time).
- Perform a self-analysis of whether the bus model in question will require a full test, no test, or partial testing; if partial testing is required, identify those tests that will reasonably be expected to produce significantly different data than was obtained in the original test.
- If the recipient’s (or manufacturer’s) analysis indicates that testing is required, then the manufacturer should contact the bus testing center to schedule the appropriate tests.
- If the analysis is inconclusive, either party may send a letter or e-mail to the FTA Bus Testing Program Manager requesting assistance in determining the bus testing requirements. This letter typically is sent by the manufacturer, as the manufacturer will usually wish to be able to sell the modified bus to other recipients. The request must include a clear and concise description of the base model and the applicable Bus Testing Report number(s), as well as descriptions of the major changes. It is often helpful to include component specifications, engineering drawings, and/or applicable analysis results or in-house test data.
- FTA will review your inquiry and any supporting documentation, and contact you if we need additional information or clarification.
- FTA will review the information provided by the questioner and will issue a determination letter, which will be mailed to the address provided in the inquiry. If a fax number was provided, a courtesy fax will be sent as well.
Process for Submitting a Bus for Testing
The process for submitting a bus for testing is administered by The Thomas D. Larson Pennsylvania Transportation Institute (PTI), the operator of the Bus Testing Program.