It was NHTSA’s intent in the NPRM to require lap/shoulder seat belts on “over-the-road” buses operated by transit agencies. Over-the-road buses used by transit agencies and over-the-road buses used by private companies for intercity transport both carry large numbers of passengers over long distances, and at highway speeds. Given the occurrence of a crash, the risk of fatality is the same for both groups of buses. It is not uncommon to see commuter express buses traveling on the highway alongside privately-operated tour and charter buses of nearly identical construction. We acknowledge that the public transit agencies’ safety record for operating commuter express service is better than the safety record shown by some private sector operators. However, given the overall similarity of the buses in construction and use, we cannot distinguish, from a public safety standpoint, good reasons for requiring passenger lap/shoulder seat belts in only privately-operated versions of the commuter express buses when the risk of rollover in a crash, risk of fatal or serious injury in a rollover, and risk of fatal or serious injury in all crashes are the same for both groups of buses.