Is the Dear Colleague letter on Pre-Award and Post Delivery Audits from March 18, 1997, the controlling document on FTAs final assembly requirements?
Yes. However, there were two subsequent letters on this subject, the August 5, 1997 letter changed the list of domestic activities required for final assembly compliance and the September 25, 1997 letter rescinded the August letter, which restored the March letter. Also note that section 3035 of the Transportation Equity Act for the 21st Century (TEA-21), contains a provision that all buses manufactured after September 1, 1999, purchased with FTA grant funds, shall conform with FTA’s Guidance on Buy America Requirements, dated March 18, 1997.