The Feb. 20 letter, sent in response to FTA's proposed rule on the use of public transit vehicles for school transportation, said school buses are built to higher construction and safety standards and implied that the vehicles do not present the challenges in loading and unloading and mixing of student and non-student populations that public transit vehicles do.

The association said it always prefers yellow school buses over other means of transport. But as this is not always possible, it suggested greater consideration was needed for what exceptions would be allowed under the law for the sake of student safety. Currently, the proposed law allows an exception "where private school bus operators in the applicant's geographic service area are unable to provide adequate transportation at a reasonable rate and in conformance with safety standards." This loophole may be too wide, the association suggested.

To make non-school buses safer, the association also asked that FTA consider adopting guidance relating to safety training for students who use public transit.

"We are concerned that students, especially those used to riding in school buses, may lack the awareness and training needed to ensure their safety when getting on or off public transit buses," wrote NASDPTS President Charlie Hood.

NASDPTS also suggested FTA consider guidance for public transit authorities regarding screening and controlling non-student riders.

Download the complete comments from NASDPTS.