NHTSA Complaint #11515965 — 2019 VAN HOOL CX45

I am writing to you on behalf of our company and the other 2000 Motorcoach operators that make up the motorcoach industry in the United States. This letter is to inform you of an extremely negligent issue related to safety risks that have been effecting our industry for quite some time and was recently over ruled by EPA. Since 2008 Heavy Duty Diesel Engines have been subject to lower emission standards and have been fitted with SCR systems to help reduce emission output. We are very committed to reducing emission, but the original ruling placed an undue burden on operators to diagnose and fix and SCR related trouble code within 4 hours before a vehicle is crippled “derated” to 5 mph while operating. Our industry expressed great concern and since this was mandated by the EPA we had to conform to the rule. However, last year we worked with EPA to develop are more appropriate “derate schedule” that would give us flexibility and more time to make the needed repair. It is almost impossible to find service facilities to repair while on the road. Most of our passengers travel long distances and many times through the night in remote areas. EPA recognized the dangers and hazards this puts us and our passenger safety at risk. So, EPA wisely rewrote the ruling giving us 80 hours prior to experiencing a derate. We were content with what was given, however there is now an added challenge that we are facing and hoping you can offer your input in regards to this subject. Now the EPA has permitted field fixes to recalibrate, we approached the Engine Manufacturers, who have out right denied the recommended changes. We feel this is extremely careless and threatens our passenger safety. We are carrying up to 56 passengers, mostly school aged children and academic/athletic groups. To suddenly slow a passenger vehicle down due to a faulty sensor is just an accident waiting to happen. If and WHEN and accident happens, that results in injury or deaths, we believe the eng