Mr. Stephen G. Sprague
Chief Operating Officer
United Motorcoach Association
113 South West Street, 4th Floor
Alexandria, VA 22314-22824

Dear Mr. Sprague,

Thank you for your January 4, 2001, and October 10, 2001, letters regarding the Safety Board's 1999 bus crashworthiness special investigation. I particularly appreciate your kind comments regarding Board staff who developed the report.

In its report, as you note, the Safety Board did not compare the safety of school buses and motorcoaches, and you ask, "whether the lack of such a comparative safety statement was an omission within the Board's report or whether it represents a considered decision." The intent of the bus crashworthiness special investigation was to determine whether additional measures should be taken to better protect bus occupants, and the Board issued recommendations intended to improve bus occupant protection. The Board did not conduct a relative safety comparison between school buses and motorcoaches.

The Safety Board believes that such a comparison would be extraordinarily difficult. Each year, few (less than 30) school bus passengers and motorcoach passengers are fatally injured in crashes, while nationwide over 41,000 persons are fatally injured in highway crashes. These exceptionally small fatality numbers for school buses and motorcoaches do not permit conclusive statistical comparisons. Furthermore, the dynamic design characteristics of the two types of vehicles are significantly different. School buses are designed to transport children to and from school and school-related activities; motorcoaches are primarily designed to transport passengers, including students, on longer trips that involve interstate and high-speed conditions.

Neither the bus crashworthiness report nor the Board report "Pupil Transportation in Vehicles not Meeting Federal School Standards" were intended to exclude motorcoaches from all student transportation activities. Rather, the Board believes that motorcoaches play an important role in student transportation when they are used for their designed purpose, particularly longer trips on high-speed roadways. As noted in our report, school bus and motorcoach travel are two of the safest forms of transportation in the United States. We believe that using these buses for their intended purpose and implementing the recommendations in the report will ensure that the outstanding safety record of these vehicles continues to improve. The Board appreciates its professional working relationship with the United Motorcoach Association and the association's members, and we look forward to further improvements in highway safety as a result of our combined efforts.

Sincerely,

(sgn) Marion C. Blakey
Chairman