Mr Andrew Imanse
Group President
Commercial Bus & Ambulance Division
Thor Industries, Inc.
9670 Galena Street
Riverside, CA 92509

Dear Mr. Imanse:

I write in response to your letter to Brian Farber with the Federal Transit Administration (FTA) requesting a determination by the FTA of whether the processes used by ElDorado National-Kansas (ElDorado) to convert an incomplete Chrysler or Dodge minivan into the ElDorado American are sufficient to meet the Buy America final assembly requirements. For the reasons outlined in the enclosed memorandum, I am pleased to inform you of FTA's conclusion that the activities that take place during ElDorado's conversion processes constitute final Assembly for minivans converted for wheelchair access.

FTA appreciates your commitment to its Buy American rules. Paramount in FTA's role as a steward of U.S. taxpayer dollars is to ensure that the use of such funds preserves and creates U.S. jobs. The intent and purpose of the Buy America requirement is to further this goal by ensuring that FTA-administered funds are used to purchase goods that are produced in the United States. FTA's commitment to ensuring Buy America compliance has resulted in a dramatic reduction in the number of waivers it has granted, from 52 in fiscal year (FY) 2010, 14 in FY 2011, 3 in FY 2012, and zero in FY 2013. Upon reviewing your request for guidance, it is apparent that ElDorado shares FTA's commitment to preserving and creating jobs in the United States.

If I can provide further information or assistance, please do not hesitate to contact me directly at (202) 366-4040.

Sincerely yours,

Peter Rogoff
Enclosure