Dear Ms. Padden:
This letter responds to your November 5, 1999, correspondence requesting that the Federal Transit Administration make a determination of Buy America compliance, as provided for in FTAís March 18, 1997, guidance letter, for the manufacture by Electric Transit, Inc., of electric trolley coaches for San Franciscoís Municipal Railway (Muni). This proposed manufacturing plan includes the installation of axles in the Czech Republic. I would appreciate your providing additional information in support of this request.
First, you state that late-stage installation would require new design and new design testing, add up to 24 months to production time, and increase the cost to Muni. Please provide specific information that supports these assertions and discuss the specific difference between a Trolley shell and a bus shell.
Second, you state that,
[t]hroughout the entire manufacturing and final assembly production process, the Trolley chassis frame is supported by the axles, lifted by the axles, and moved on the axles. The Trolley axle positions are the only suspension points on the chassis frame designed to bear its weight. Indeed, support of the Trolley at any point other than the axle positions will apply unnatural loading and transfer weight to the components not designed to carry the increased load, resulting in permanent distortion.
Please provide documentation in support of this assertion and explain why use of dummy axles would not adequately support the trolley chassis frame until final assembly. Also, please provide information detailing the implications of installing the axles at the beginning of final assembly.
Third, you state that axle removal and reinstallation requires highly trained technicians and equipment not available in the U.S. and that there is a high risk of distortion in late-stage axle removal. Please discuss Muniís recent axle removal and reinstallation on the two prototype vehicles in light of these comments.
And finally, please provide your proposed manufacturing plan, including a station-by-station breakdown of activities as they occur in both the Czech Republic and the U.S.
I look forward to receiving the above-referenced information and responding to your request promptly. If you have any questions, please do not hesitate to contact Meghan G. Ludtke at (202) 366-4011.
Very truly yours,
Gregory B. McBride
Deputy Chief Counsel
cc: Rene Marler, Regional Counsel