BALTIMORE COUNTY PUBLIC SCHOOLS iiams, Fa, Superintendent » 6901 North Charles Steet * Towson, MD» 21204 DanyIT. April 27, 2022 Ms, Leslie Dews Deputy Administrator, Field Operations Maryland Department of Transportation Motor Vehicle Administation {6601 Ritchie Highway N.E, Glen Bumie, Maryland 21062 Re: Response to Results of Maryland Department of Transportation Motor Vehicle ‘Administration Independent Inspection of the Baltimore County Public Schools’ Bus Fleet Dear Ms. Dews: ‘This letter isin response to your letter dated April 14, 2022, regarding the Maryland Department of Transportation Motor Vehicle Administration (MDOT MVA) report, “Baltimore County School System Bus Inspection Review” and your request for a response by April 27, 2022, to the following issues and recommendations: According tothe BCPS inspection document, the fuel strap on bus #4897 was certified as being repaired on October 26, however, MDOT MVA inspectors noted during the November 10 inspection that three out of four broken ful straps ‘were braken but secured by the fuel eage. (Page 3) Likewise, for bus #4854, the BCPS inspection document certified repair on Nowwmber 4, however, MDOT MVA inspectors found on November 10 that all fuel ‘straps on the tank were broken a the tack weld, being held in by the fuel cage. (Page 3) MDOT MYA recommends BCPS and aif local school systems ensure that Issues with fuel straps are identified and recorded on all inspection documents and repaired within the specified timeftame under the regulations. (Page 4) MDOT MYA recommends BCPS regularly audit inspection and repair documents lo ensure they are accurate and complete. (Page 4) MDOT MYA recommends BCPS leadership review the discrepancy identified on ‘the repair documents forthe two vehicles examined on November 1010 determine why repairs were ceriffied as complete when the repairs had not been made, Page 4) ‘As noted in your letter and again in the report, the independent inspection of BCPS' bus fleet ‘vas initiated on November 22, 2021. Late in the report it stated the inspections spanned fom Raising the ar, Closing gaps Preparing or or ftureResponse to Results of Maryland Department of Transportation Motor Vehicle Administration Independent Inspection of the Baltimore County Public Schools’ Bus Fleet Page 2 ‘April 27, 2022 November 12,2021 through January 14, 2021. Yet, the report referenced inspections that cceurred on November 10, 2021, specifi to fuel tank straps. BCPS has no record of any official inspection that occurred on November 10, 2021; however, BCPS invited MDOT MVA to visit ‘one of our bus facilities to assess potential issues with fuel tank straps on November 10, 2021, as ‘was indicated inthe report, BCPS is unaware of any feedback ~ writen or verbal ~that was provided by MDOT MVA on November 10, 2021, regarding the condition ofthe fuel tank straps fon any BLP school buses. Further, MDOT MVA cited a discrepancy between the eported date of repair and the status of fuel tank straps as observed on November 10, 2021. Its BCPS’ contention that any ofthe 52 fuel tank straps that were repaired or replaced proactively and out ofan abundance of caution by [BCPS were not in violation of COMAR, as they were secure, by definition, and reviewed by BPS fleet supervisory staff, In fact, he MDOT MVA report notes on page 3, *... MDOT MVA_ inspectors noted during the November 10 inspection that three out of four broken fuel straps were broken but secured by the fuel cage.” However, in no documentation provided by MDOT MIVA during the random inspection process ~ or predating it, given the November 10, 2021 date ~ were fuel tank straps cited as major or minor defects, Two buses were noted in MDOT MVA’s report as having issues with the stated day of repair: 4897 and 4854. It should be noted that these buses only have two (2) fuel tank straps, not four (4), as indicated in MDOT MVA’s report. ‘Attached are theofficial inspection results from MDOT MVA for both of those buses; neither shows an inspection date of November 10, 2021 by MDOT MVA. If MDOT MVA believed the fel tank straps on any buses were of issue on November 10, 2021, why were none immediately cited and/or taken out of service by MDOT MVA? Itwas not until Novernber 19, 2021, when [BCPS was notified by MDOT MVA that they considered the fuel tank straps defective and ‘would commence a random inspection of all BCPS school buses. n the nine-day interim, BCPS voluntarily and progctively reexamined any 2015 Thomas buses with a wheelchair lift in the feet and then replaced, and/or repaired ther fuel tank staps ater consultation with the Maryland State Police and the manufacturer, before entering ther back in serviee. [BCPS contends and is confident that had there been a safety issue or clear violation of COMAR, MDOT MVA would have immediately removed any questionable school buses from service rather than wait nine days to act ~ from November 10, 2021 to November 19, 2021. To specifically respond to MDOT MVA"s questions regarding the certification of repais prior to November 10, 2021, on buses 4897 and 4854 as part ofthe type “B” inspection and as previously stated, it was BCPS" contention that the fuel tank straps in question were not in violation of COMAR, as they were secure, by definition. BCPS leadership has reviewed the discrepancy identified by MDOT MVA on the intemal Type “B" Inspection forms used for buses 4897 and 4854, BCPS previously shared and as was noted in the MDOT MYA report, the recognized ‘opportunites for improvement and growth and has changed its procedures and forms to reflect items that require review or repair in etter alignment with COMAR. BCPS tained fleet supervisory staff and implemented the use of these new forms prior tothe March 2022 Type "B” Inspection eycle. Raising the bar, Casing gps Preparing for om futureResponse to Results of Maryland Department of Transportation Motor Vehicle Administration Independent Inspection of the Baltimore County Public Schools” Bus Fleet Page 3 ‘April 27, 2022 Further, BCPS is secking clarification from MDOT MVA regarding the certification of inspections; COMAR references inspection certifications in 11.19.04.05 as needing to be submitted within 10 days, with “certification” defined as, “a signed statement, made under penalty of perjury, on a form provided by the Administration.” BCPS received the “Type B School Vehicle Inspection Certification” form from MDOT MVA on November 26, 3021 and returned it December 8, 2021 (8 business days), which is within the 10-day COMAR timeframe ‘Any online submissions regarding individual buses are not the Inspection eertfleation, to BCPS* knowledge. Infact, regarding the specified timeframe under COMAR, BCPS contends MDOT MVA’s online certification statement and process is controversial. Local school systems must acknowledge a statement to submit inspections that indicates certification with completed repairs, bt they may have open 30-day repairs. The MDOT MYA online system defaults every certified inspection as “Pass; if local education agencies like BCPS submit an inspection with a 30-day repair open in MDOT MVA's database to meet the cited timeframe in that system, 00, ‘we would be knowingly submitting false information, Thus, BCPS requests clarity regarding the timeframe in question and te official certification document and process from MDOT MVA. CPS is also requesting MDOT MVA clarify the fotal number of major and minor defeets noted a 8 result ofthis random inspection. In “Table 1 - MDOT MVA Independent Inspection Results, ‘of BCPS Fleet” it was noted that total of 40 major defeets and 105 minor defects were identified. However, on page 3 ofthe Baltimore County School System Bus Inspection Review, it was noted 39 major defects and 109 minor defects were found. BCPS believes the correct number of major defects to be 39 but is requesting MDOT MYA verify both this figure and the correct number of minor defeets identified and documented during the random inspection since there appears to be reporting discrepancies. [BCPS values its partnership with MDOT MVA and appreciates the support and feedback provided during this process. As recommended by MDOT MVA, BCPS will rezuarly audit inspection and repair documents to ensute their accuracy and completeness. ‘Thank you for the opportunity to provide feedback of our own regarding MDOT MVA’s random inspection of the BCPS schoo! bus flet, and BCPS looks forward to future partnerships that emphasize safety and our shared commitment to Maryland students. We also look forward to MDOT MVAs response to clarify our questions, you have any further questions as result of this response, please do not hesitate to contact me. Sincerely, fice of Transportation Raising he bar, Csing gaps Preparing for ow fareResponse to Results of Maryland Department of Transportation Motor Vehicle Administration Independent Inspection of the Baltimore County Public Schools’ Bus Fleet Page 4 ‘April 27, 2022 Enclosures; MDOT MVA School Bus Portal Record ~ Bus #4854 MDOT MVA School Bus Portal Record ~ Bus #4897 2021-2022 Type B Certification Letter Email from MDOT MVA to BCPS ~ Dated November 26,2021 ‘Type B School Vehicle Inspection Certification ~ Signed by BCPS ~ Dated ‘December 8, 2021 Copies to: Mr. MeKandy Gale, Manager, MDOT MVA. Me. 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Graf, Michae! A e 2021-2022 Type 8 Certification Letter ‘tach BA Cosdoce [CAUTIONS The ema liking lnk, especially from unknown senders. sted from outside your organuation. Exercite caution when opening attachments Good mocning Dr. Grim, ‘Attached isthe Type 8 certilcaion letter, Please sign the letter and emalit tome, f you have any questions, please ‘Thank you. Marte Tore Mo oe Aaaryoorenrmunss | Vee eet &Comptance Marland Deparment of Transportation Motor Vehicle administraton (601 Ree Highway NE len Bune Maan 21062 teas rsistrdand (210) 768-7401 (0) Website | Facebook {werGovernor Hogan is committed to outstanding customer service. Tellus how we are doing lick here, SL traveler informs sie ww. d51.0 AY res caaer neemtomon x pring Dis amat LEGAL DISCLAIMER - The Information contained inthis communication (including any attachments] may be confidential and legally privileged. 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Dr. Jess Gri ‘9610 Pulaski Park Drive Suite 219 Balimore MD 21220 1 School Ve As roquized by the Code of Maryland Regulations Tie 11.19.04 (School Vehicle Inspection), 1 hereby certify, under penalty of perjury, all vehicles owned by or contacted to Baltimore County Public Schools have had their reqived annual Certified Type B Safety Inspection for school ‘year 2021 - 2022 and a record of the inspection is avaliable For review during regula business Inout. (Type I Stool Buses smut e inspected pursuant o COMAR 11.14.04 and Type II ‘School Vehicles mast be inspected pursuant fo COMAR 11.14.02). Vehicles that have not been {ngpecid are tobe taken out of service and notify The Administration (MDOT MVA) until a ‘Type B inspection is performed, Please attach a ist of vehales that di not gt inspected in siti to this eter, 1/s/r0 allen Gee Dito Sapir of Tanspertaonfepresetaive (ts mc nie, Menlens2100 | 41076700 | NOPSAIMVA | Meroe 0472489 | memento