Let's not confuse inspectors who may be conducting emissions tests and annual automobile inspections with Law Enforcement Inspectors who are on the roadside and at bus company garages conducting safety inspections on drivers and buses everyday

On board computers was mentioned, hours of service has been mentiond. My honest opinion is in 395.2 and in the interpretation of question 2 that bothers me to no end. The conditions that will allow a driver to mark a tour of duty as off duty time. In the motorcoach industry a company can have the driver mark stops as off duty time and then extend the drivers day. As long as you do not drive the 10 hours a driver could be on duty 20 or more hours. It is only the on duty not driving and the driving that count toward the 15 hour limit. It has been discussed around here a lot. I have gotten our company to back off on this issue to some degree. I am asked repeatedly where does it say 15 hours. Well if drivers are marking there stops as off duty time then there day will be extended. We have customers who want coaches for 15 ot 16 hours and if we do not try to honor their request then you loose the charter to comptetion because I know of other companies in the area will do it. I just do not like the fact that this interpertation is part of the rules. We drive live people around and drivers get tired and drivers are not robots by I am afraid that to the customer who cares about the saftey just get us there.

The USDOT is being unrealistic, and also not focusing on the real issues. First, forcing installation of seatbelts on buses will require the removal and retrofit of seat-belt-fixtured seats on the current fleet. Now what happens: the floor mount points of new seats are not designed to handle the twisting loads caused by the passenger weight rotating forward, so the mounts will fail and the seat assemblies start hurtling around inside the bus; there is no assurance that passengers will all use them (what is the driver going to do, go back and be the seat-belt policeman?); if a passenger damages a belt installation so that it becomes inoperative on tour, is the bus now declared out-of-service? Is the driver expected to replace the belt installation from a box of spares carried on board? How is this going to play out?

Drilling new mount holes into the floor will require through-bolts and hefty underfloor retaining plates to withstand the loads put on the fixtures; this cannot be done where the seat mount interferes with a bulkhead. So other than putting in a false floor of steel plate, I do not see how this can be achieved. And if you do not replace the seats in the current fleet, then you end up with two types of seats in the industry. There is only one manufacturer of compliant belted seats, who hardly has enough manufacturing capacity to replace the industry's fleet. So where are all these new seats going to come from? DOT has not thought this one through.

It should also be remembered that the USDOT rules ironically also lead to fatalities. A bus crash in the mountains of Colorado most likely took place when the driver elected to continue on his path rather than run an alternate route between ranges that would have taken him outside danger, but have placed him 51 miles over-limit. While the NTSB study focused on the retarder and gear shifting, the issue was really: what is the bus doing on that road in the first place? The upshot: Death by Regulation.

Finally, the claim of "unsafe carriers" remains a red herring, a bit like crying "communist" in the Fifties. The DOT likes larger carriers as they are have nice offices in which to sit and conduct paper reviews. The DOT dislikes owner-operators. Yet we have seen some awful wrecks flowing from the failed practices in larger carriers, those with "satisfactory" ratings from the USDOT. Invariably the deaths result from roll upsets, where the personnel are ejected from the bus through the mandatory opening windows. Let's remember that the opening-windows rule goes back to gasoline buses with low sills; what elderly passenger is going to go clamber out the high window of a modern tour bus? None. So make the windows smaller and permanent; if the passengers stay inside, they typically survive just fine. Opening windows leads to Death by Regulation.

Finally, concentrate on driver education. Driving prudently does more for passenger safety than any single other feature. You can install all the fancy technology you want; if the driver insists on being foolish, eventually a wreck will be the result. The USDOT fails to grasp this fundamental truism.

In the interest of driving safety there are many automobiles being equiped with "heads-up" display. I have never heard mention of this being a viable option on commercial vehicles such as tractor-trailer combinations or transit vehicles Has any organization or manufacturer done trials on this type of system in the above application?