The Pioneer Valley Transit Authority’s (PVTA’s) “PVTA Agency Safety Plan” did not identify potential safety hazards and ways to mitigate them, specifically electrical fire hazards, within PVTA’s fleet of battery electric buses (BEBs). In addition, PVTA could not demonstrate that its contracted operating companies completed Hazard Mitigation Action Worksheets to address the potential safety hazards specific to battery and electrical fires, which differ from fires associated with traditional gasoline or diesel vehicles.
If the “PVTA Agency Safety Plan” does not identify potential safety hazards or how to mitigate them, PVTA may end up storing its BEBs in close proximity to its buses, which could increase the likelihood of fire spreading to PVTA’s whole bus fleet. According to the National Fire Protection Association and the Federal Transit Administration (FTA), electrical fires involving batteries can burn for extended periods and can potentially reignite up to 22 hours after the initial incident.
If PVTA does not identify causes of potential battery and electrical fires and does not put measures in place to mitigate the occurrence of fires, then PVTA assumes a higher risk of adverse situations, including prolonged fires, damage to vehicles and facilities, service disruptions, and injury to employees and members of the public.
Authoritative Guidance
Section 673.25 of Title 49 of the Code of Federal Regulations (CFR) states,
(b) Hazard identification.
(1) A transit agency must establish methods or processes to identify hazards and potential consequences of the hazards.
(2) A transit agency must consider, as a source for hazard identification . . . Data and information provided by an oversight authority, including but not limited to FTA, the State, or as applicable, the State Safety Oversight Agency having jurisdiction. . . .
(c) Safety risk assessment.
(1) A transit agency must establish methods or processes to assess the safety risk associated with identified hazards.
Section IV of the “PVTA Agency Safety Plan” states,“PVTA will fully use all available data and sources to identify current and potential hazards. These sources are incorporated in any Risk Assessment Matrix (RAM) analysis.”
Reasons for Issue
PVTA officials indicated that limited resources and staffing hindered PVTA’s capacity to fully recognize and address potential safety hazards related to BEBs. The officials further suggested that the PVTA Safety Committee monitors emerging safety trends to evaluate and manage all safety hazards.
Additionally, PVTA did not demonstrate that it maintained effective controls during the audit period to ensure that its contracted operating companies completed the required risk assessment matrices for BEB-specific hazards.
Recommendations
- PVTA should update the “PVTA Agency Safety Plan” to incorporate risks and strategies for hazard mitigation for BEBs, specifically for battery and electrical fires.
- PVTA should implement controls to identify and mitigate potential causes of electrical fires in its fleet of BEBs.
- PVTA must ensure that its contracted operating companies assess the risks related to BEBs in order to comply with Section IV of the “PVTA Agency Safety Plan.”
Auditee’s Response
PVTA strongly disagrees with the statements included in this section.
PVTA officials did not make such a statement. As shown below . . . PVTA has resources and staff to recognize and address potential safety hazards related to the BEBs.
The PVTA’s Public Transit Agency Safety Plan (PTASP) is a policy document. The intent of the Plan is to establish a venue for safety issues to be discussed and addressed. PVTA has oversight controls in place to ensure contracted operating companies meet all safety requirements including those associated with BEBs specific hazards. The PTASP was not intended to be a document to capture every safety procedure in every department or contractor across the Authority, rather it is a blueprint to guide establishment procedures for each operating company to follow in establishing training and oversight practices.
PVTA has recognized BEBs potential safety hazards, not only to the facilities but to the staff as well as to the passengers. PVTA has worked diligently to ensure compliance with regulations and at the same time secure funding to conduct the required studies to identify and to mitigate any risks associated with the phased transition of BEBs into PVTA transit operations. As such PVTA has taken several approaches to address these hazards included but not limited to the following:
Operations and Maintenance [(O&M)] Facilities
Facility design phase actions were taken to provide for a safe and code-compliant BEB charger installation. A review of each of the transit facilities was done prior to the installation of the initial set of chargers. The operating contractors from each site have been involved in each step of design and planning to ensure all levels of the organization are in sync with PVTA’s plan and approach. . . .
Springfield O&M Facility at Cottage Street.
- Provided a facility-wide electrification design study and code compliance review.
- Met with the municipality’s Chief Fire Marshall to discuss appropriate fire suppression modification and sprinkler density for BEB areas; the fire department’s plan of attack in the case of a BEB fire; and the need for installing smoke vents to the facility.
- Met with the Building Department and Electrical Inspector to discuss and confirm sprinkler density design parameters for BEB storage and maintenance areas; discuss emergency shut-offs for the building in case of a bus fire; discuss installation of emergency stops for electric bus dispensers; as well as the design for the incoming new electrical service.
- Designed a sprinkler system providing 0.7 [gallons per minute (gpm)/square foot (sf)], utilizing . . . sprinkler heads for Cottage Street BEB storage & maintenance areas—exceeding the current building code minimum for indoor parking, which is 0.20 gpm/sf. Northampton’s system is being updated to 0.7 gpms/sf with the 2026–27 FTA Bus & Bus Facilities Grant (design is underway).
- Provided additional smoke hatches in the bus storage area, which is above and beyond what is required in the building code.
- Ensured that all charging equipment was rated for a wet area.
- Interconnected charging system power sources with building fire alarm system. Specified general power de-energization of newly constructed BEB charging areas if sprinkler systems are activated (with the exception of life safety systems and emergency lighting).
- Designed proper clearances between stored buses and clear paths for efficient bus exiting from the facility in the case of a bus fire based on designer best practices review.
- Provided the Fire Department with the ability to manually disconnect the charging systems power supply from a single coordinated location on site when deployed for a fire alarm as requested.
PVTA’s Cottage St. designer reviewed the above approach with FM Global. Hydraulic calculations were performed side-by-side, comparing PVTA’s designer’s sprinkler approach to FM Global’s recommendations. PVTA’s designer’s approach exceeded the FM Global guidelines and FM Global is in concurrence with PVTA’s sprinkler design.
Northampton O&M Facility . . .
Code Red Consultants [was subcontracted] to do the Code Compliance study to inform the design. The Code Compliance study included a fire flow test to verify that the fire protection/sprinkler systems met [National Fire Protection Association] code requirements. Ensured that all charging equipment was rated for a wet area. Installed e-stops at each dispenser, and a power disconnect at each charger.
A 100% electrification design study was not conducted for Northampton. The Northampton facility parcel is too small to support 100% electrification. However, an electrification design study is currently being done as PVTA explores the expansion/relocation of this operation.
[University of Massachusetts (UMass)] O&M Facility . . .
Code Red Consultants [was subcontracted] to do the Code Compliance study to inform the design. The Code Compliance study included a fire flow test to verify that the fire protection/sprinkler systems met [National Fire Protection Association] code requirements. Ensured that all charging equipment was rated for a wet area. Installed e-stops at each dispenser, and a power disconnect at each charger.
A 100% electrification design study was not conducted for UMass. The UMass facility parcel is too small to support 100% electrification.
Since PVTA was only installing two charging dispensers at each facility (Northampton and UMass) there was no funding for upgrading from the code required 0.20 gpm/sf to the best practice 0.70 level. PVTA immediately programmed a capital improvement project for Northampton to upgrade the sprinkler system with the next charger installation (currently in design as part of the Bus and Bus Facility grant awarded to PVTA in November 2025).
Please note, in addition, the BEB diagnostic and charging systems that come with the buses/chargers also have the ability to manage potential fire risk by continuously monitoring cell and module temperatures, voltage and current, state of charge and charge rate and cooling system performance. When limits are exceeded, the system can reduce charging power, shut down charging entirely, isolate parts of the battery and trigger alarms or fault codes. These systems are currently operational at each site.
Lastly, PVTA is finalizing the solicitation package for a BEB charging management software, a digital solution designed to manage, monitor, and optimize the operations of BEBs charging stations, as part of the core functionalities of the charging management software, it will include, among other functionalities, a monitoring and control module that will enable real-time oversight of charging stations—tracking status, performance, and energy use—to quickly resolve issues and maintain network efficiency.
Operators, Utility Workers and Maintenance Technicians
All employees receive basic electrical safety awareness training covering the topics below at initial hire and annually as refresher training. The goal is to ensure all employees appreciate the hazards in the workplace, recognize trouble signs, understand basic emergency actions, and do not inadvertently interfere with the safety programs. . . .
In addition . . . as part of the Bus Operator Training Program, bus operators are trained in the procedures to follow in the event there is dashboard warning light on the BEBs and the steps to follow to notify the dispatcher of any issue that might develop during electric vehicle route operations.
Passengers
To mitigate on the road hazards, during the summer of 2023 PVTA visited the fire departments of the PVTA member municipalities to conduct an orientation to the PVTA fleet and to provide the manufacturer’s First Responder Literature for all types of vehicles specifically the electric fleet. All training information was placed on a shared link Folder titled PVTA Emergency Response – Bus. This link was provided to the various fire department contacts to distribute to their respective firefighters.
Posters were created that show the identifying decals for diesel, hybrid electric and electric buses. The posters also included high level information from the Emergency Response Guide. The visit included bringing two buses, an electric and diesel. Each firefighter was given a tour of the vehicles identifying the major components, including the electric components and shut down locations.
In addition to the hands-on training provided above, PVTA has provided evacuation and shutdown procedures training to first respondents in the Pioneer Valley Region. Each of the 4-hour training courses were conducted by a manufacturer (New Flyer) employee, including a facility tour, traditional classroom sessions, and practical review with a New Flyer BEB. This training consisted of incident procedures for thermal events for both buses on route as well at a structure; incident response procedures for collisions (front, side and rear); incident response submersion and incident response battery spill.
Emergency evacuation requirements are dictated by FTA, [the National Highway Traffic Safety Administration] and other compliance agencies. Evacuation is about moving all persons out and away from the vehicle, not whether passengers can remain in a bus if a fire occurs. What or how the bus is powered is immaterial. Door, portal or other egress engineering requirements dictate passenger safety requirements; they are universal regardless of the propulsion type. . . .
Regarding the Safety Committee, the finding appears to suggest that as part of the Public Transit Agency Safety Plan (PTASP), the Safety Committee would have direct, day-to-day oversight of specific Battery Electric Bus–related processes and procedures. While all safety matters fall within the purview of the Safety Committee, it is important to clearly distinguish the respective roles and requirements of the Public Transportation Agency Safety Plan (PTASP) and the Safety Committee as established under 49 CFR Part 673.
49 CFR Part 673 establishes a regulatory framework for system-level safety oversight, including the identification of risk-reduction measures in federally mandated focus areas and ensuring that safety concerns raised by frontline employees are communicated to the agency’s chief executive. A Safety Committee established under PTASP is a federally mandated body with specific requirements for joint labor-management representation.
By design, the PTASP Safety Committee is a joint labor-management committee focused on:
- Identifying and recommending risk-based mitigations or strategies to reduce the likelihood and severity of consequences identified through the agency’s safety risk assessments.
- Identifying mitigations or strategies that are ineffective, inappropriate, or not implemented as intended; and
- Identifying safety deficiencies to support continuous improvement.
These issues may be identified directly by Safety Committee members, but they are also informed by ongoing oversight of activities conducted by PVTA staff and individual operators. Because the Safety Committee is composed of an equal number of management and frontline employees—who, due to the nature of their operational responsibilities, may not be readily available on short notice, it is necessary for PVTA staff and operations management to assume responsibility for routine, day-to-day oversight.
In addition, 49 CFR Part 673 requires the Safety Committee to develop a Safety Risk Reduction Program and to establish annual Safety Performance Targets. . . .
Safety Risk Reduction Program: Large urbanized area providers must include a safety risk reduction program for transit operations to improve safety performance by reducing the number and rates of safety events, injuries, and assaults on transit workers. The safety risk reduction program must, at a minimum:
- Address the reduction and mitigation of vehicular and pedestrian safety events involving transit vehicles that include safety risk mitigation;
- Address the reduction and mitigation of assaults on transit workers that includes safety risk mitigations;
- Include the safety performance targets set by the Safety Committee for the safety risk reduction program performance measures established in the National Public Transportation Safety Plan. These targets must be set—
- Based on a three-year rolling average of the data submitted by the large urbanized area provider to the National Transit Database (NTD);
- For all modes of public transportation; and
- Based on the level of detail the large urbanized area provider is required to report to the NTD. The Safety Committee is not required to set a target for a performance measure until the large urbanized area provider has been required to report three years of data to the NTD corresponding to such performance measure.
- When the Safety Committee, as part of the transit agency’s safety risk reductions program, identifies and recommends safety risk mitigations based on a safety risk assessment, the transit agency must include or incorporate by reference these mitigations in the [agency safety plan], and the Accountable Executive must implement these mitigations.
Source: FY2025 Contractor Manual – Public Transportation Agency Safety Plan 22-18
As part of PVTA mandated FTA oversight requirements, PVTA has contractor oversight procedures that include comprehensive safety, operational, and maintenance monitoring activities. Key oversight tasks include regular vehicle inspections, operator training certifications, key performance indicators review and analysis, reporting of customer feedback, reporting of incidents and accidents and, compliance with PVTAs PTASP and Safety Management Systems (SMS).
Early in the transition to an alternative fuel fleet, PVTA worked with staff, contracted operators and consultants to execute the tasks needed to identify and address the risks associated with transitioning the fleet to BEBs. These actions and the resulting activities and reports are mentioned earlier in this memorandum.
Auditor’s Reply
We acknowledge the improvements PVTA made to its facilities and the updates it made to the “PVTA Agency Safety Plan” in 2025, including the Safety Risk Reduction Program, aimed at minimizing potential risks. However, it is important to note that these initiatives were not in place during the audit period and in some cases, were not implemented until after a thermal event occurred inside PVTA’s garage in March 2025. Additionally, we note that PVTA first purchased BEBs in December 2016.
During our audit exit conference on February 5, 2026, PVTA officials indicated that they would need to hire more people to recognize and address trends related to the identification of safety hazards in BEBs. We believe that an important component of any Safety Risk Reduction Program is hazard identification. Although PVTA has developed policies and procedures regarding hazard identification in its Safety Risk Reduction Program, we requested and were not provided with any evidence that safety hazards related to BEBs were identified by PVTA or its contracted operating companies.
In its response, PVTA indicated that safety hazards could be detected by the Safety Committee or through ongoing oversight activities conducted by its staff members and individual operators. However, during our audit, we requested all risk assessment matrices for the identified BEB electrical safety hazards, but these were not provided. Additionally, we reviewed all Safety Committee meeting minutes from the audit period, and the Safety Committee identified no safety hazards related to BEBs.
While PVTA is working to improve its facilities and the “PVTA Agency Safety Plan,” we emphasize the importance of identifying the causes of potential battery and electrical fires and implementing measures to mitigate these risks.
Based on its response, PVTA is taking measures to address our concerns in this area. As part of our post-audit review process, we will follow up on this matter in approximately six months.
| Date published: | July 1, 2026 |
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