We wrote this letter in response to Minister Roland Hache's letter to us of January 7, 2010, in which he said he was going keep the mixed tires on the Multi Function Activity Vehicle even though there is no scientific evidence to support the theory that mixed tires on MFAVs is safe.
Click here to read the Minister's January 7, 2010 letter to us.
Subject: Response to Minister Hache's letter on Jan.7, 2010
Date: Sun, 10 Jan 2010 17:02:12 -0300
Dear Minister Roland Hache;
This is in response to your letter sent via email January 7, 2010. There are a few issues that really bother us and we feel that we have to respond. We believe that you are getting bad advice from your Communications Director and your advisors, as well as the employees at the Department of Transportation who are involved in this file. We believe they know fully well what they are saying to you is inaccurate but they are counting on you to back them up. Unfortunately for them, all the evidence we have, including your own Department's Education Act, correspondence and reports proves that they are giving you the wrong information.
For example, you say in your letter that this tire configuration of mixed tires has proven safe "for years". We cannot believe that you were advised to make such an inaccurate statement to we parents who know the story of these MFAVs inside out.
Are you not aware that that the mixed tire policy you are referring is for yellow school buses only, not 21 passenger MFAVs?
Are you not aware that the 21 passenger MFAVS have only been the Department of Education for one year, not "years"?
Can you not see the difference between a yellow school bus and a 21 passenger MFAV which is much smaller than a school bus and are rear wheel drive on a one ton chassis?
If you are aware of all these facts, why would you say that a yellow school bus tire policy is acceptable for a 21 passenger MFAV when you have no scientific evidence to back up such a statement?
And how can you say that a policy which was developed for yellow school buses has proven safe for "years" for 21 passenger MFAVS when these MFAVs have only been part of the Department of Education's fleet for one year?
It is false and misleading to say that the policy of combining mixed tires has been "safe" for years on a 21 passenger MFAV when you've only had them in your fleet for one year. Your advisors know that there has never been a scientific study of mixed wheels vs winter tires on these vehicles in Canada or the United States. They cannot in all good conscience back up your statement that the mixed tire policy is "safe" on 21 passenger MFAVs so they are putting words in your mouth which are based on fiction and hoping we don't catch them in a lie.
For example, on November 24, 2009, Gary Spencer, Assistant Director, Operations / Transportation at the Vehicle Management Agency, Department of Transportation wrote to Michelin Tires seeking its opinion on the use of mixed tires (attached). In the letter he called the 21 passenger MFAV a "bus" ten times, he confirmed that these vehicles were a new addition to your fleet and that there has never been a scientific study of these tires. In their response, Michelin and Goodyear also reconfirmed the lack of scientific research to back up their opinion on mixed tires.
You also call the 21 passenger MFAV a "bus". Do you, or do you not know that these 21 passenger MFAV's are not a "bus" according to your own Pupil Transportation Regulations of the New Brunswick Education Act and your own Policies 512 and 513? In fact, the 21 passenger MFAVs are Extra Curricular Activity Vehicles. If you do know they are not "buses", why do you, and your Director of Communications and others including Gary Spencer at DOT, and your paid consultant David Hoar of Motion Design Assoc. continue to call the 21 passenger MFAV a "bus"? This is very misleading because it confuses the parents, the public, the media and the experts with whom you are dealing at Goodyear and Michelin.
Also, how can you say this is the safest way when this is a new vehicle with no known scientific testing in North America.
Ironically, we know of a school in New Brunswick which used these vehicles in the past years when it used to be owned privately by school officals. Until we discovered the tire problem on the Bathurst High School MFAV in October 2009, this 21 passenger MFAV used winter tires on all axles. Attached are photographs of this vehicle taken by Isabelle Hains. You can clearly see there were winter tires on all axles.
We don't understand why there is so much trouble to get a simple test done, especially when offered for free, saving tax payers an estimated $250.000. You say that the students safety is your first priority. If it is such a priority, shouldn't the test be done? There should never be second guessing. The opportunity is there to have the test done for free which will remove the second guessing and everyone in North America will know once and for all whether winter tires or mixed tires are the safest tires for 21 passenger MFAVs.
Since the banning of 15 passenger vans in NB and other provinces, there will be a lot more of these vehicles on the road. Wouldn't you feel more at ease knowing that you have scientific research to back up your public statements about the use of winter tires on these MFAVs? We know that we will feel more secure and so will every other parent whose child travels in these vehicles. The children depend on adults to make the safest decision. The test should be done and the bus used should be the one donated to BHS in memory of our boys. We parents will hire a Class 2 driver who will drive the MFAV with no passengers all the way to Michigan. We will pay all the expenses including extra insurance, gas, etc.. We are doing this in memory of our boys who were killed two years ago this week on January 12, 2008, and for the safety of all children in North America.
We implore you to consider scientific testing of the tire configurations on the 21 passenger MFAV as the only way to ensure the safest combination of tires. Whether the scientific evidence points to traction and ribbed or winter tires all around, we will accept the results of these tests but we cannot accept the current state of affairs.