One of the most important goals of any trade association is to advocate for the industry it represents. At the National School Transportation Association (NSTA), we pride ourselves on being an effective advocate for private school bus contractors around the country. This also includes working with the National Association for Pupil Transportation (NAPT) and student transportation state directors when school bus safety is being discussed. We take our role of representing pupil transportation seriously, and for this reason we engage in policy debates in several places, one of which is the regulatory arena.
Regulatory analysis is not usually an activity that gets much attention from the general public. We are on constant guard when it comes to regulatory issues; as we know, the yellow bus is a constant target. For purposes of this conversation, understand that our legislative activity comes in the form of lobbying members of Congress to support or oppose a piece of pending legislation. Having myself testified before the House Transportation and Infrastructure Committee in July, I fully acknowledge the difference between regulatory and legislative activity.
That is why I am highlighting our work on commenting on pending rules and regulations being considered by federal departments and agencies. Our comments help shape the landscape of pupil transportation in all fleets in the U.S., even if they are far removed from the spotlight of our nation’s Capital.
Last year alone, NSTA sent comments to regulators on 12 separate occasions. For example, we filed comments with the National Highway Traffic Safety Administration (NHTSA) and the Federal Motor Carrier Safety Administration (FMCSA) regarding the implementation of Commercial Motor Vehicle Automated Driving Systems (ADS).
That particular rulemaking process recognized the vital stake that school transportation has when it comes to the integration of ADS into our school buses. As such, NSTA focused on educating regulators on the importance of other automated vehicles being able to detect the unique stopping patterns of a school bus. We also pointed out that precautions must be taken to ensure automated systems are not vulnerable to cyber security threats. Finally, NSTA stood firm on its position that regardless of the ultimate level of automation a school bus employs, a human “driver” must always be present on a school bus.
NSTA also filed comments with federal regulators in support of reducing Commercial Driver’s License (CDL) testing barriers by allowing drivers to take knowledge tests in another state, as well as supporting the FMCSA’s proposal to increase the “on-duty” hours of service for short-haul commercial drivers (i.e. school bus drivers).
Finally, NSTA submitted other comments to FMCSA supporting their proposal to identify non-preventable crashes on an operator’s Behavior Analysis and Safety Improvement Category (BASIC) prioritization algorithm and making the Crash Preventability Demonstration Program permanent. We previously submitted comments in July 2015 regarding non-preventable crashes and urged FMCSA to address the issue of crash preventability as it places an undue regulatory burden on carriers, and severely affects their Safety Management System percentile rankings.
Those involved with pupil transportation know that impeccable safety rankings are not the exception, but rather the standard for school transportation operators. NSTA sought to emphasize to FMCSA that removing non-preventable crashes from a school bus contractor’s ranking was simply an issue of fundamental fairness.
We continue to advance in many ways the interests of school transportation through our advocacy efforts. While you may not see them being boasted about on social media or as a trending story in the news, understand that they have a cumulative impact in supporting private school bus contractors.