- A New Age of Enforcement: Adjusting to Remote and Offsite Investigations & How to Prepare By:
Presented as part of ABA’s BISC & BusMARC 2021 Virtual Safety & Maintenance Series The American Bus Association’s Bus Industry Safety Council (BISC) and Bus Maintenance Repair Council’s (BusMARC) 2021 Virtual Safety & Maintenance Series offered a sequence of educational webinars early this year, covering a variety of industry-related topics. As part of its ongoing webinar series, the ABA hosted a virtual meeting with presenters Catterson Oh and Danielle Smith, transportation specialists with the Federal Motor Carrier Safety Administration’s (FMCSA) Compliance Division. Oh and Smith focused on COVID-19 national emergency investigative process updates including changes to the FMCSA investigative procedures due to COVID-19, recordkeeping and documentation as the result of COVID-19, and providing accurate documentation for FMCSA investigations. Changes to Investigative Procedures as a Result of the COVID-19 Health Emergency In May 2020, the FMCSA released guidance allowing investigators to conduct remote onsite investigations. These remote onsite investigations are intended to follow the same general process as offsite investigations with the exception that most of the investigation is now completed remotely. According to Oh, May 2020 resulted in a significant expansion to the FMCSA’s remote functionality. While motorcoach operators may not have seen any investigations in the last year, Oh noted that due to this expanded functionality, companies should expect a considerable increase in the number of investigations moving forward. “In terms of the offsite investigations with this pandemic, the policy with this particular type of investigation has not changed,” Oh said. “The offsite investigation will still be recommended for carriers that meet the appropriate criteria for this population of carriers.” Although carriers will not receive a rating from an offsite investigation, offsite investigations may be converted to onsite remote investigations under certain circumstances. Carriers with investigations that are converted onsite may be issued a Safety Fitness Rating. Overview of Investigation Process Safety Investigator (SI) will conduct an initial phone call with the carrier to introduce themselves, and review the reason for the investigation and next steps. 2. SI will email the carrier an Initial Contact Letter that will go over initial documents being requested. 3. Carrier will upload the initial documents to the Safety Measurement System (SMS). 4. After SI receives the initial documents, they may request additional documents via a Document Request Letter. 5. SI may contact the carrier via phone and email throughout the investigation. 6. Once SI has completed the investigation, they will request a closeout meeting with the carrier, which can be done via phone, Microsoft Teams, Skype, or other platform. 7. Carrier may receive a Safety Rating upon completion of the Remote Onsite Investigation. According to Oh, carriers subject to investigation will receive a phone call, followed by an initial contact letter, from an FMSCA Safety Investigator (SI) introducing themselves, the reason for investigation and next steps. Once a carrier has received this letter, that carrier’s information will need to be uploaded into the FMCSA Safety Measurement System (SMS). After receiving the initial documents, an SI will review the content to determine if additional documentation is required. If additional documentation is needed the SI will issue a “document request letter.” “This is where things start kind of diverting from the normal way of doing things,” Oh explained. “Especially when you have performed onsite investigations.” An SI will start contacting the carrier via phone and e-mail throughout the investigation. In a normal onsite investigation, the SI would be with the carrier in person to answer questions and provide additional guidance. Once the SI has completed their investigation, they will request a close out meeting with the carrier. This can be done over the phone or, more likely, in a video conferencing setting. At this point, the carrier may receive a safety rating upon completion of the remote onsite investigation. Once the SMS has processed the information, the carrier will be able to access their dashboard, track investigation progress, check due dates and required documents, view call-to-action reminders, upload documentation, and learn to use data to increase safety performance. After the SI has reviewed all of the required documents, they will send the carrier a request for a meeting to close out the investigation. Typically, this is done onsite, face-to-face however, since the onset of the pandemic, closeouts are now performed virtually. Reinstatement After Voluntary Revocation of Operating Authority In March 2020, the FMCSA issued multiple exemptions in response to the national health emergency. One of those exemptions included waiving the $80 reinstatement fee for carriers who opted to voluntarily revoke their Passenger Operating Authority. Carriers with a USDOT pin can login into their profile, update their registration information, and complete an MCSA-5889 form, a Motor Carrier Records Change. Carriers without a USDOT pin, can register and request a pin number through the FMCSA website. Before submitting a request, carriers will need to file a BOC-3 (Designation of Process Agent), confirm insurance filings are up to date, and make sure that their USDOT number is reinstated and activated. Once these items are completed, the reinstatement request is going to be put on hold until the carrier has everything submitted properly. “If all is submitted and you do have to pay that fee, then you’ll get it reinstated no later than the fourth business day after the payment is processed,” Smith explained. “You can request that the fee is waived, you’re just going to submit it through EMC’s e-mail address rather than doing it through the normal process online.” FMCSA Ratings The FMCSA issues three types of ratings. Satisfactory, conditional, or unsatisfactory. Satisfactory means that there are safety systems in place and they all appear to be working. Conditional means that there are safety systems in place, but there are breakdowns within some of those systems. While carriers are still able to operate with a conditional rating, some choose not to do so and would rather upgrade their score. Unsatisfactory ratings mean a carrier is considered unfit and are not allowed to operate after that time. “All of the critical violations are listed within the Read More >
- Rejuvenate Your Fleet — IT’S TIME! By:
Are your buses spending a lot of time in the shop? Do they keep breaking down in the middle of service? Or maybe you have noticed the exterior/interior body begin to deteriorate? If any of these scenarios sound familiar, then your fleet may be due for a mid-life rehab/overhaul. A process that strips down the buses to fix and/or replace worn components with all new parts. The best thing is that the useful bus life is extended at less than half the cost of a new bus. Customers describe the end result of the buses “Like New.” The ideal candidates are seven- to nine-year old buses with about 250,000 miles. It’s like a face lift…but for a bus! It is no surprise that transit fleets are in need of mid-life overhauls with how much they endure. Hundreds if not thousands of riders are in and out of the buses all day, every day. Transit buses are operated 24/7 with no weekends or holidays off. The daily wear and tear significantly impact the health of the buses over the years. However, each geographical area where the buses are operated determine which components endure more wear. For example, the northern states see more structural damage due to the large amount of corrosion on the buses. The winter time is harsh on the vehicles and many times the vehicles may look visually good, but there are hidden issues. Corrosion tends to hide behind exterior panels, undercarriage and below the floor. We have worked on buses where all of the sub-floor is rotted due to unrepaired water leaks. This does not only look unappealing, but also creates a safety issue for riders. Alternatively, in warmer states like Florida and Arizona we see additional strain on HVAC systems due to the extensive use. It requires cooling systems to be serviced and replaced more frequently. Before we begin a mid-life overhaul we like to assess the fleet to identify recommended repairs. The most common elements of a mid-life overhaul are the following: engine repower and compartment, suspension rebuild, undercarriage, HVAC system, repair/replace flooring, new seat inserts, body repairs, structural repairs, driver’s area, wheelchair system and full paint and decals. The fleet assessment also allows us to inspect the buses for possible risk areas and if the buses are good candidates for the mid-life overhauls. We will not recommend buses for overhauls when they have exceeded the recommended age. Also we will not recommend it, if we see costly repairs like structural or frame damage because it will not be worth it. After the assessment, we can design a customized mid-life overhaul program for the fleet based on the mechanical, body exterior and interior needs. All of this may sound like a lot of work? Well you are right! Most transit agencies are not equipped to take on these projects because of the highly intensive labor, shop space and experienced technicians requirements. On average the whole process takes about six to eight weeks depending on the scope of work being performed. This timeframe is much less if you compare it with ordering a new bus from the OEMs. Especially with the national production shortages going on across the industry. When a bus is completed, it goes through an extensive quality control process, including a final inspection and long test drive. The transformation from when a bus arrives to our facility to when it leaves is truly amazing. It is very rewarding to follow the bus through the process and see it improving every day. What other benefits can you expect from performing an overhaul? First and foremost, it will save your maintenance team time and money. Transit agencies have reported cost savings and reduction of vehicle breakdowns and service hassles after completing an overhaul program. This allows the agencies to keep less buses in the shop and more on the road serving riders. Overall improving reliability and safety. An added bonus is upgrading equipment while the buses are going in for refurbishment. Some common upgrades are Security Cameras, Driver Protection Barriers, Air Filtration and Wheelchair Systems. Midlife overhauls are key to keeping buses running and providing service. The goal is to prevent the buses from breaking down causing service interruptions. Don’t wait to rejuvenate your fleet – ITS TIME! CoachCrafters, Inc. has been offering midlife overhauls for over 30 years. We have customized programs that include all makes and models. We want our customers to receive the maximum value of their investments, by saving time and money. As well as, helping them provide a better riding experience to their riders. Iriz Guerrero is sales and marketing manager for CoachCrafters. CoachCrafters is happy to help and serve the public transportation industry. Please make sure to give us a call at 833-559-7679 with any of your specific maintenance needs, or visit www.coachcrafters.com for more information.
- County of Hawai‘i MTA Goes with Hydrogen Fuel Cells as Part of Master Plan By:
As part of its 2017 commitment to transition to zero emission fleets, The County of Hawaiʻi Mass Transit Agency (MTA), in partnership with the Hawaiʻi Natural Energy Institute (HNEI) and U.S. Hybrid, has taken delivery of its first hydrogen fuel-cell-powered bus. Slated for operation later this spring, the 21-passenger 2014 El Dorado Aero Elite was accepted by the Hawaiʻi County Council in 2019 as a donation from HNEI. “The Hawaiʻi Natural Energy Institute has been working hard to find a way for us to become more self-sustaining and transition away from traditional fossil fuels,” said John Andoh, Mass Transit Administrator and General Manager of the MTA. “They began discussions with MTA in 2010 to investigate a potential hydrogen bus pilot because we have geothermal energy, and we have great ways to convert that geothermal energy into hydrogen.” Under the leadership of Mitch Ewan, this project has made great strides in making the project from concept to reality starting with the construction of a new hydrogen station and obtaining the funding to get a pilot bus. Originally purchased as a gasoline-powered vehicle by HNEI using funds from the Energy Systems Development Special Fund, the U.S. Department of Energy, and the Office of Naval Research, the bus was converted by U.S. Hybrid to hydrogen with a new state-of-the-art 40 kW U.S. Hybrid fuel cell as its proprietary electric drive system. Until completion of a base yard in Kailua Kona (tentatively scheduled for 2025), the bus will be operated and maintained by Roberts Hawaiʻi, one of Hawaii’s largest employee-owned tours and transportation companies, when maintenance can then be transitioned to the MTA. Until then, the bus will be maintained and fueled at HNEI’s state-of-the-art hydrogen station at the Natural Energy Laboratory Hawaiʻi Authority (NELHA). “We are also about to construct battery electric charging facilities at our Hilo yard,” Andoh said. “This will enable us to charge those electric buses when they come towards the end of 2023. We will be installing the same battery electric infrastructure as our Kailua-Kona base.” The MTA is also awaiting delivery of two 19-passenger 2012 El Dorado Aero Elite buses converted for hydrogen fuel-cell power scheduled to be delivered later this year as a donation from the State of Hawai’i surplus office. These buses previously was earmarked to operate within the Hawai’i Volcanoes National Park. U.S. Hybrid is currently installing the hydrogen drive systems. These developments are a result of the commitment made in 2017 by the mayors of the state’s four counties to transition their public transit fleets to zero emissions by 2035. Subsequently, MTA is working in partnership with the Hawai’i Department of Transportation and the neighboring islands of Maui and Kaua’i to implement a zero-emission bus (ZEB) rollout plan, which includes the operation of battery-electric buses on each island. Hawai’i County is leading the charge on an electric bus procurement for 12 buses with 75 options split between the three counties. As part of the rollout, MTA is currently testing both hydrogen fuel-cell electric buses and plug-in battery-electric buses to determine which zero emission buses best meet the county’s needs. “We’ll have both type of vehicles,” Andoh explains. “Long term, we are going to be procuring additional battery electric buses through a private public partnership. We are also going to be applying for future Low or No grants through the Federal Transit Administration to replace our diesel and diesel hybrid fleets with either hydrogen or battery electric buses. This pilot for both fuels will give us an opportunity determine which buses best meet MTA’s needs related to operations, maintenance, cost, and other considerations.” MTA will begin phasing in additional zero-emission buses as part of future bus purchases in 2023. The county is also in the process of implementing recommendations from its Transit and Multi-Modal Transportation Master Plan, which was officially adopted in 2018 and began implementation in 2021. According to Andoh, the objective of the Master Plan is to rebuild the transit system, implement new routes, expand services, implement new multimodal opportunities, such as bike share, partnerships with transportation network companies, redesign the share drive program, and increase paratransit services. That includes buying more passenger amenities such as bus shelters and benches, and adding technology such as automatic vehicle locators, Wi-Fi, and electronic fareboxes to the system. “Our ridership has declined significantly over the last 10 years due to service reliability issues,” Andoh explains. “However, we are actively trying to rebuild that ridership. And now that we have a Master Plan in place and we have begun to implement those elements, we are starting to see a return in ridership and service levels.” The implementation of the restructured transit service supports the efforts of Mayor Mitchell D. Roth to increase access to public transit for all island residents, enabling increased economic development, improved access to employment, shopping, medical, education, and assist the County in achieving sustainability goals regarding transportation. Official components of the Master Plan are: Goal One: Make riding transit easier, reliable, and more desirable than other options. Goal Two: Create a transit system to serve the employment and social needs of all people Goal Three: Implement technology to provide real time transportation information Goal Four: Create transportation hubs and bus stops with amenities that provide rider comfort and safety and that help support community and village gathering places Goal Five: Phase system implementation in a fiscally sustainable manner Actions based on the Transit and Multi-Modal Transportation Master Plan that have since been implemented or are in the process of being implemented include development of a new brand and logo, doubling bus frequency, additional routes and service areas, fare-free service, streamlined transfers, a partnership with HIBIKE bike-sharing, website upgrade, providing General Feed Transit Specification to Google, Bing, and Apple to allow for the addition of bus routes on their map applications, and the continued replacement of aging transit fleet with electric, hydrogen, and diesel hybrid electric buses. Continued improvements based on the Transit and Multi-Modal Transportation Master Plan will progress throughout 2022 and Read More >