August 11, 2009
Christopher L. Crassweller
Daimler Buses North America Ltd.
350 Hazelhurst Road
Re: FTA’s Final Assembly Requirements
Dear Mr. Crassweller:
I write in response to your letter dated June 22, 2009, in which you request that FTA confirm certain manufacturing procedures regarding the final assembly processes of Daimler’s buses.
According to your letter, Daimler Buses North America (Daimler) transports its Orion bus frames from Canada to your United States (U.S.) facility in the State of New York. In order to avoid exposing the interior of the bus frame to the elements, you install the doors in Canada, and then remove and reinstall the doors in the U.S. You interconnect the door operating system (air and electrical) in the U.S.
In January, 2000, FTA advised Orion Bus Industries that a similar practice did not violate FTA’s final assembly requirements. As long as you remove, reinstall, and interconnect the door operating systems in the U.S., consistent with the final assembly requirements listed in paragraph (b) of 49 CFR 661.11, Appendix B, your practice remains consistent with FTA’s Buy America requirements. Feel free to contact Jayme Blakesley at firstname.lastname@example.org if you have any questions.
Scott A. Biehl
Acting Chief Counsel