2.12 Student Transportation. Introduction

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1 Introduction Figure 1 At 31 Marc 2003, tere were approximately 84,000 students enrolled in scools in te Province of Newfoundland and Labrador, of wic an estimated 57,000 were transported by scool buses. Tese students are transported over a total of about 37,000 kilometers eac day. Under te Scools Act, 1997, scool boards are required to arrange for te transportation of students to and from scools were deemed necessary. Te boards are required to ensure tat all veicles engaged to carry students are in good mecanical condition and ave adequate liability insurance. As well, te scool boards are required to ensure tat an appropriate scool bus safety program is offered to students wo are transported by bus. Included in te operating costs of scool boards are expenses related to student transportation suc as payments to private contractors for scool buses to transport students and/or te operating of scool board run bus programs to transport students. At te time of our review, tere were 11 scool boards operating in our Province. Te related 11 scool districts are sown in Figure 1. Provincial Scool Districts Auditor General of Newfoundland and Labrador 201

2 Funding for te operation of scool boards in te Province is provided in te form of grants from te Department of Education. Te Minister of Education as te autority to issue policy directives to te scool boards wic would include directives pertaining to te transportation of students to and from scools. Consequently, troug budgetary, policy setting and monitoring processes, te Department of Education as a sared responsibility wit te scool boards for student transportation in te Province. Student transportation may be provided by scool boards, private contractors or a combination tereof. Board operated systems use teir own scool buses wit drivers wo are employees of te board. Private contractors provide te buses and drivers. Of te 11 scool districts in te Province, 4 districts use only private contracted services, 2 districts use only board-owned and operated buses, wile 5 districts use a combination of bot. In July 2001, te Minister of Education issued a directive Scool Bus Transportation Policies setting conditions under wic funding is provided to scool boards and te general operating perimeters for scool bus transportation services to students attending primary, elementary and secondary scools. Te directive provided for grants to fund board-owned and private owned busing systems wit a number of related conditions and operating requirements. Tese conditions included suc tings as: a minimum distance of 1.6 kilometers from a scool for busing, te approval of private contracts by te Department of Education, a 14 year maximum age limit for scool buses, a scool bus safety program, te tendering of private contracts in accordance wit te Public Tender Act, and tat all veicles used for student transportation conform to te requirements of te Higway Traffic Act and Canadian Standards Association standards. Standards for all drivers and veicles in our Province are contained in various regulations under te Higway Traffic Act suc as te Higway Traffic Driver Regulations, Bus Regulations, Veicle Regulations, Commercial Veicle Maintenance Standards Regulations and Official Inspection Station Regulations. At te time of our review tere were 11 scool boards operating in te Province. Subsequent to our audit, te Province establised a new governance structure wic consolidated te existing 11 scool boards, effective 1 September Under te new board structure, tere are 5 boards: te Labrador Scool Board; te Western Scool Board; te Central Scool Board; te Eastern Scool Board; and te Conseil Scolaire Francopone Provincial. 202 Auditor General of Newfoundland and Labrador

3 Scope and Objectives We completed a review of student transportation in Marc Te objectives of our review were to: review student transportation costs in te Province; determine weter tere are adequate systems and practices in place for te safe transportation of students; and to ensure compliance wit legislative responsibilities. In addition to a review at te Department of Education, we also reviewed matters pertaining to student transportation in District # 2 Nortern Peninsula/Labrador Sout Scool Board, District # 3 Corner Brook-Deer Lake-St. Barbe Scool Board, and District # 10- Avalon East Scool Board. Conclusions Under te Scools Act, 1997, scool boards are required to arrange for te transportation of students to and from scools were deemed necessary. Te boards are required to ensure tat all veicles engaged to carry students are in good mecanical condition and ave adequate liability insurance. As well, te scool boards are required to ensure tat an appropriate bus safety program is offered to students wo are transported by bus. Department of Education officials indicated tat a number of years ago a decision was made in certain scool districts to ave board-owned buses. Te reason given at tat time was tat it was believed to be ceaper for te board to operate teir own buses rater tan contract out student transportation to private contractors. Tis as since been proven to not be te case. Budget information sows tat te average cost to operate board-owned buses during te scool year was $44,069 versus $30,024 for contracted buses. 350 or 34% of all licensed buses are owned by scool boards. Furtermore, a financial report issued by Government in January 2004 indicated tat approximately one tird of board-owned buses (i.e. approximately 120 buses) will ave to be replaced over te next 3 years. Officials indicated tat a new bus costs approximately $80,000. Tis would equate to approximately $9.6 million. Auditor General of Newfoundland and Labrador 203

4 Tere are no standards specific to scool bus drivers included in legislation under te Scools Act, 1997 in tis Province and tere is no current policy direction from te Department of Education setting out te employment and training requirements for scool bus drivers. Furtermore, te Department of Education does not require te scool boards to ceck for criminal records of all bus drivers. We found tat a bus driver in te Avalon East Scool District wo ad a number of convictions for suc matters as multiple impaired driving carges, multiple break and enter carges and multiple teft carges, was not prevented from driving a scool bus. We identified a situation at te Avalon East Scool Board were irregularities in te bus contract tendering process resulted in te board paying $1.8 million more annually tan in te previous years' contract. Department of Education officials indicated tat tis issue was being reviewed, in consultation wit Treasury Board Secretariat and te Department of Justice. Findings and Recommendations Student Transportation Costs Declining student enrolment in past years as partially driven canges in te number of scools tat are operating in te Province. In many cases, scools ave been closed and students are bussed to a neigbouring scool. Some increase in transportation costs can be attributed to tis as fewer students can walk to scool. Officials indicated tat oter factors wic impact on student transportation costs are increases in salaries and benefits for scool bus drivers, an increase in direct costs suc as fuel and insurance, and an increase in te requirement for safety features on te scool bus. A summary of student enrolment and student transportation costs by scool district for te scool years ended 30 June 1999 to 30 June 2003 is included in Figure Auditor General of Newfoundland and Labrador

5 Figure 2 Student Transportation Cost By Scool Year and District 30 June ($000s) Scool District Student enrolment 97,401 93,957 90,167 86,898 84,268 Scool District 1 Labrador $ 1,571 $ 1,761 $ 1,775 $ 1,567 $ 1, Nortern Peninsula / Soutern Labrador Corner Brook / Deer Lake / St. Barbe 1,313 1,388 1,420 1,517 1,461 2,424 2,418 2,632 2,741 2,796 4 Cormack Trail 1,901 1,880 1,923 1,959 2,062 5 Baie Verte/ Central/ Connaigre 2,861 2,885 3,034 2,987 3,331 6 Lewisporte / Gander 3,593 3,808 4,015 3,751 4,576 7 Burin Peninsula 1,964 2,193 2,241 2,435 2,417 8 Vista 1,840 1,880 1,862 1,741 1,794 9 Avalon West 3,941 3,780 3,745 3,931 4, Avalon East 6,438 4,810 5,060 6,485 6, Conseil Scolaire Francopone Provincial $ 27,994 $ 26,959 $ 27,847 $ 29,289 $ 31,391 Breakdown by system: Board-owned system $ 10,967 $ 11,763 $ 12,530 $ 12,248 $ 13,875 Private contract 17,027 15,196 15,317 17,041 17,516 $ 27,994 $ 26,959 $ 27,847 $ 29,289 $ 31,391 Sources: Scool Board Financial Statements/ Department of Education statistics Auditor General of Newfoundland and Labrador 205

6 Our review of te information included in Figure 2 indicated te following: Altoug student enrolment as declined over te past number of years, student transportation costs are increasing. In te scool year, te total cost of student transportation was $28.0 million wereas total student transportation costs for te scool year ad increased to $31.4 million. Tis is an increase of $3.4 million or 12.1% in five years, wile student enrolment as decreased by 13,133 or 13.5% during tis same period. Furtermore, te Department of Education as budgeted student transportation costs for te scool year at $33.6 million wic results in a furter increase of $2.2 million over te scool year. Of te $3.4 million increase in student transportation costs over te last five years, $2.9 million relates to increases in board-owned busing costs wereas only $0.5 million of te increase relates to private contracts. Officials of te Department of Education indicated tat a number of years ago a decision was made in certain scool districts to ave board-owned buses. Te reason given at tat time was tat it was believed to be ceaper for te board to operate teir own buses rater tan contract out student transportation to private contractors. Tis as since been proven to not be te case. In fact, te cost to operate a board-owned bus is generally iger tan tat of a contracted bus. Budget information provided by officials of te Department of Education for te scool year, sows tat te average budgeted cost per board-owned bus is $44,069, wile te average budgeted cost per contracted bus is $30,024 a difference of $14,045 per bus. Reasons for tis difference would include a iger salary rate and benefits received by scool board workers (e.g. drivers, mecanics), and te total distance for bus runs serviced by board-owned busing eac day is muc iger at 26,031 kilometers versus 10,588 kilometers for bus runs in areas serviced by private contractors. Anoter significant contributing factor to te iger costs of operating scool board buses relates to te fact tat te boards ave newer buses tan te private contractors. We obtained license information on scool buses from te registration system of te Motor Registration Division (MRD) of te Department of Government Services. Figure 3 summarizes licensed scool buses by model year and also provides a breakdown on te number of board-owned buses and private owned buses. 206 Auditor General of Newfoundland and Labrador

7 Figure 3 Licensed Scool Buses by Model Year 30 September 2003 Ownersip Breakdown Model Total Total % Board-owned % Private % Year % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % % Total 1, % % % Source: MRD Scool Bus Inspection Reports 30 September 2003 As Figure 3 sows, tere were 1,044 licensed scool buses in te Province at 30 September 2003 and scool boards own te majority of te newer buses. Details relating to tese 1,044 are as follows: 694 (66%) of te 1,044 buses licensed in te Province are owned by private contractors wile only 350 (34%) are board-owned. 739 (70%) were 1993 model year or older. 593 (80%) of tese buses were owned by private contractors wile te remaining 146 (20%) were board-owned. Auditor General of Newfoundland and Labrador 207

8 128 (12%) were 2000 model year or newer. 121 (95%) of tese buses were board-owned buses and only 7 (5%) were owned by private contractors. Te average age of all licensed scool buses was 11 years. Te average age of board-owned buses was 7 years wile te average age for buses owned by private contractors was 12 years. A financial report issued by Government in January 2004 indicated tat approximately one tird of board-owned buses (i.e. approximately 120 buses) will ave to be replaced over te next 3 years. Officials indicated tat a new bus costs approximately $80,000. Tis would equate to approximately $9.6 million. Student Transportation Systems Te Department of Education is responsible for maintaining a liaison wit te Scool Boards in te interpretation and application of Departmental policies on student transportation. Tere are two types of student transportation provided by te 11 scool boards in tis Province. Tere are board-operated systems were te scool board owns and operates a fleet of buses. Te buses are purcased and maintained by te board and te drivers are employees of te board. Tere are also busing services provided to a scool board by a private contractor wo owns and operates te scool bus. Generally te student transportation service is tendered and a contract is awarded for a period of tree years. Te contract may be extended for an additional period upon agreement by bot parties. Of te 11 scool districts in te Province, 4 districts (districts # 4,9,10 and 11) use only contracted services for student transportation, 2 districts (districts #1 and 7) use only board-owned fleets, wile te remaining 5 (districts # 2,3,5,6 and 8) use a combination of board-owned and contracted services to provide transportation to te students in teir district. 1. Student Transportation Policy and Procedures To ensure te safety of te Province's scool cildren, it is vital tat tere be sound systems and practices in place for student transportation. In order to identify and assess te systems and practices in place, we performed reviews of matters pertaining to student transportation at te Department of Education and in District # 2 Nortern Peninsula/Labrador Sout Scool Board, District # 3 Corner Brook-Deer Lake-St. Barbe Scool Board, and District # 10- Avalon East Scool Board. Our review indicated te following: 208 Auditor General of Newfoundland and Labrador

9 Only te Nortern Peninsula/Labrador Sout Scool District ad detailed policy and procedures in place governing student transportation. Officials in te Corner Brook-Deer Lake-St. Barbe Scool District and te Avalon East Scool District indicated tat tey were in te process of developing student transportation policy and procedures. A district policy and procedures manual would serve to outline te responsibilities of te various parties involved wit te transportation of students including te students, parents/guardians, bus drivers, and scool principals and staff. 2. Driver Employment Standards and Training Driver employment standards and training are necessary to ensure te safety of scool cildren riding in te Province s scool buses. Tese standards and training are designed to address suc areas as valid licence, appropriate driving record, knowledge of scool bus safety, ow to deal wit inappropriate cild beaviour, defensive driving training, and first aid certification. (i) Driver Employment Standards Our review indicated te following: Tere are no standards specific to scool bus drivers included in legislation under te Scools Act, 1997 in tis Province. Also, tere is no current policy direction from te Department of Education setting out te employment and training requirements for scool bus drivers. Tere was a manual issued by te Department in 1987 relating to employment standards for all scool bus drivers; owever, it is out of date and not used. Te 1987 manual outlines requirements for bus drivers wic include: a minimum age of 18 years; one year's driving experience; a medical certificate of pysical fitness; a valid license (pass written exam and oral test); and a knowledge of bus and equipment maintenance, safety and passenger control. Te only requirement in scool board contracts is for te contractor to provide drivers wo are of good caracter, capable, sober and reliable and tat scool bus drivers ave a driver s license necessary to operate a scool bus. Auditor General of Newfoundland and Labrador 209

10 Te Department of Education does not currently require te scool boards to ceck for criminal records of all bus drivers. However, we were informed tat many boards do obtain a certificate of conduct before bus drivers are ired. During our review of te Nortern Peninsula/Labrador Sout Scool District we found tat te Board did not obtain a certificate of conduct for its bus drivers wile in te Avalon East Scool District and te Corner Brook- Deer Lake-St. Barbe Scool District, te Boards do require certificates of conduct. Figure 4 Te Department as not provided any guidance as to wat would constitute an unacceptable criminal record. Terefore, inconsistencies may exist as to wat a Board would consider as an unacceptable criminal record. For example, we found tat a bus driver at te Avalon East Scool Board ad a number of convictions for suc matters as multiple impaired driving carges, multiple break and enter carges and multiple teft carges wo was not prevented from driving a scool bus. Figure 4 contains information on selected scool bus driver requirements in Canada including first aid training, a criminal record ceck, a driving record ceck and a medical certificate. Canadian Scool Bus Driver Requirements 2004 Jurisdiction Criminal Record Ceck Driving Record Ceck Medical Certificate First Aid Certificate Newfoundland and Labrador No Yes Yes No New Brunswick Yes Yes Yes Yes Prince Edward Island Yes Yes Yes Yes Nova Scotia Yes Yes Yes Yes Quebec Yes Yes Yes No Ontario Yes Yes Yes No Manitoba No Yes Yes No Alberta No No Yes No Saskatcewan No No Yes No Britis Columbia Yes Yes Yes No Yukon Yes Yes Yes Yes Source: Survey obtained from te Department of Education 210 Auditor General of Newfoundland and Labrador

11 Te survey indicates tat wile most jurisdictions in Canada require a criminal record ceck, our Province does not. (ii) Driver Training Our review indicated te following: Neiter te Department of Education nor te tree scool boards reviewed ave establised continuing education/training requirements for scool bus drivers. Officials of te Department of Education were aware tat some scool boards do offer courses suc as te Newfoundland and Labrador Safety Council's bus driver course and first aid periodically. We found tat formal driver training programs at te tree scool boards reviewed varied as follows: In te case of te Avalon East Scool Board, wic contracts out all of its student transportation, te Board was not aware of any formal training being provided by te contractors. Individual contractors may provide training to teir drivers; owever, te Board was not aware of te frequency and extent. Furtermore, we were informed tat te Board does not offer its own training due to a lack of available funding from te Department of Education. Tere was no evidence of any formal training provided to scool bus drivers at te Nortern Peninsula/Labrador Sout Scool District. Te only formal training provided to scool bus drivers at te Corner Brook-Deer Lake-St. Barbe Scool District is a first aid program; owever, two of te board's scool bus drivers ad not attended te latest training session and terefore ad not maintained teir certification for first aid. 3. Route Planning In order to identify te appropriate number and types of veicles required for student transportation, it is necessary for te boards to know te number and ages of students wic require busing. Based upon tis information, route planning can ten occur. Auditor General of Newfoundland and Labrador 211

12 Route planning involves taking te information available on students requiring transportation and ten creating and sceduling bus routes and stops for eac scool year to accommodate tese students. Part of a successful route planning process would involve a regular and consistent monitoring and evaluation process. It is important to know te numbers of students traveling on buses to avoid overcrowding on one and as well as ensuring tat te system remains efficient. Our review indicated te following: (i) Training Altoug boards review teir routing scedules annually, te Department of Education as not provided route planning guides or training to assist Board staff in route planning. Planning guides and training could result in identifying inefficiencies in routing scedules, especially in ligt of declining student enrolments and te closing and consolidation of scools. Of te tree scool districts we reviewed, only te Avalon East Scool Board ad a computerized system to assist in route planning. (ii) Courtesy Seating Contrary to te Department of Education's policy to not provide busing to a student living closer tan 1.6 kilometer walking distance from teir scool (courtesy seating), two of te tree boards reviewed, Nortern Peninsula /Labrador Sout Scool District and Corner Brook-Deer Lake- St. Barbe Scool District, do provide tis service. We were informed by officials of te Avalon East Scool District tat, commencing in te scool year, te District ceased providing tis service. Terefore, not all students in te Province are being treated in te same manner wit respect to courtesy seating as outlined in te Department of Education policy. Officials at te Department of Education were of te opinion tat all scool boards were providing courtesy seating, contrary to te Department's official policy. 4. Scool Bus Safety Training Scool Bus Transportation Policies were issued in July 2001 by te Minister of Education under te autority of te Scools Act, Tey require tat scool boards, as a condition for funding of student transportation, introduce a scool bus safety program wic would include but not be limited to class room instruction related to scool bus safety, scool bus boarding and unloading drills, were necessary instruction of drivers in good driving abits and first aid, and supervision of loading and unloading of scool buses. 212 Auditor General of Newfoundland and Labrador

13 None of te tree scool districts we reviewed ad te required scool bus safety program in place. Individual scools and scool bus contractors may offer scool bus safety training periodically; owever, tis training is not part of a scool board program. In te case of te Corner Brook-Deer Lake-St. Barbe Scool District we were informed tat tere ad been a program in place but tat it ad been discontinued for quite some time. Compliance wit te Public Tender Act Scool boards are required to invite public tenders prior to entering into a scool bus contract in accordance wit te Public Tender Act. Te Public Tender Act requires te Boards to invite tenders were te cost of goods and services is more tan $10,000. Te Act provides exceptions were tenders may not be required to be invited and in tese cases te Minister of Government Services must be informed. Te Minister in turn will table a report in te House of Assembly. We reviewed scool bus contract tendering practices at tree scool districts and found te following. (i) Avalon East Scool District During our review, we identified a situation were irregularities in te bus contract tendering process resulted in te Board paying $1.8 million more annually tan in te previous years' contract. Details are as follows: A tender closed on 18 July 2003 for a tree-year busing contract to commence in September For 9 of te contracts tendered, te Board received only a single bid, all from te same company (comprised of te owners of private busing companies wo ad bid separately on prior years' contracts). Te Department of Education did not approve te awarding of te 9 contracts because: if bids on tese 9 contracts ad been accepted, student transportation costs would ave increased by a total of $5.4 million over te tree year life of te contracts ($1.8 million per year); and te bids submitted by te new company effectively eliminated all competition. On 24 July 2003, te Board was instructed by te Department to issue a new tender call and to add a clause to te tender indicating tat bids would not be accepted from groups of companies. Te Board was also instructed to reduce te contract term from tree years to two years. Auditor General of Newfoundland and Labrador 213

14 A tender closed on 8 August 2003 for a tree-year busing contract (contrary to te two-year period directed by te Department of Education) to commence in September Te Department of Education did not approve te awarding of te contracts because officials ad concerns tat tere may ave been communication and/or collusion involved wit te bidding process. In addition to a bid from te new company, (te group of companies), wic was rejected because it did not meet te tender specifications, anoter company submitted bids. Department officials expressed concerns tat tis company ad no prior experience in student transportation and tat te bid on all te contracts may ave been an apparent attempt to create a multiple bid situation. Officials determined tat te bids received from tis company were set at a consistent amount iger on eac route tan te original bids received. On 12 August 2003, te Department of Education decided to cancel te tender process and ave te Board negotiate te contracts wit te prior route older in eac case. Te Department considered te wole matter as an emergency under an exemption in te Public Tender Act. On 13 August 2003, officials from te Department and te Board started te negotiation process and on 5 September 2003, just prior to te start of te scool year, completed te negotiation and awarded te contracts to te individual bussing companies wic ad eld te prior contracts. Te total value of te contracts negotiated was $12.5 million over a tree year period ($4.2 million per year) and will result in an increase from prior years' contracts of approximately $5.4 million over te tree-year period. Te Minister of Government Services, and terefore te House of Assembly, was not informed of tese exemptions as required by te Act. Department of Education officials indicated tat tis issue was being reviewed, in consultation wit Treasury Board Secretariat and te Department of Justice. 214 Auditor General of Newfoundland and Labrador

15 (ii) Corner Brook-Deer Lake-St. Barbe Scool Board Details of public tender issues identified at tis scool board are included in Part 2.7 of tis Report. (iii) Nortern Peninsula /Labrador Sout Scool District In all instances reviewed, routes were tendered and te lowest bid was accepted. Recommendations Te Department of Education, in consultation wit te scool boards, sould: Develop standards for scool bus drivers wic would assist in determining te acceptability of drivers and ensure tat criminal record cecks are regularly made to ensure tese standards are applied by te scool boards on a Province-wide basis. Develop and provide an appropriate training program for all scool bus drivers, students and scool board staff. Department s Response Develop standards for scool bus drivers wic would assist in determining te acceptability of drivers and ensure tat criminal record cecks are regularly made to ensure tese standards are applied by te scool board on a Province-wide basis. Te department, in consultation wit scool board officials and personnel in oter government departments, will develop policies to ensure tat bus operators meet acceptable standards and tat caracter cecks are conducted on all bus drivers. Tese measures will include amending specifications for bus tenders and scool board / operator busing contracts. Te department as a provincial busing policy in place and we will continue to work wit board staff in amending and administering tese policies. Auditor General of Newfoundland and Labrador 215

16 Develop and provide an appropriate training program for all scool bus drivers, students and scool board staff. Te department will work wit te applicable scool board personnel to develop and/or purcase training and safety awareness programs, update te drivers training manual, conduct in-servicing and purcase oter scool bus safety materials for distribution to scools. Te Department notes tat your report doesn t mention some very key aspects of our scool busing service in tis province. To demonstrate tis, we would like to igligt te following as examples: Board owned and operated systems were establised over te years because of situations trougout te province were operators ad exclusive bidding rigts due to lack of competition; consequently, costs were escalating to te point were, at te time, it was more economical for boards to operate teir own systems. It also served as an alternative means to provide te service if contracted service became cost proibitive. Te Department acknowledges tat Board owned systems, on average, are more expensive tan contracted services and will review options to ensure cost effective services are provided witin te parameters imposed by collective agreements. Te decline in student population as ad minimum positive impact on busing expenditures. Te costing summary included in your report fails to reference tat te costs of scool busing ave increased during te period and will continue to increase due to te uncontrollable price of fuel and insurance. Nor does it mention tat costs increased due to implementing K to 12 busing in St. Jon s. As contracts are up for tendering, departmental and board personnel review te number of eligible riders, duration of te run, scool opening and closing times, etc. It is done first and foremost wit student safety in mind and as well, optimizing operating efficiencies and cost effectiveness. For example, between 1998/99 and 1999/2000 scool years, te provincial cost of busing dropped by $1.6 million. Tis was due to te combined efforts of te scool boards and te department to optimize operating efficiencies witin some scool districts. Tese efforts continue annually. 216 Auditor General of Newfoundland and Labrador

17 Altoug it isn t sanctioned by te department, some scool boards do offer courtesy seating to students were space is available and no additional costs are incurred. Scool boards are required to comply wit te Public Tender Act wen contracting for scool busing services. Te Department will continue to work wit te scool boards to ensue compliance wit te legislation. Wit respect to te (irregularities in te bus contract tendering process) in te former Avalon East Scool Board, tis matter is currently wit te Department of Justice for teir consideration and advice. Te Department notes tat current contracts require te operator to a) provide drivers wo are of good caracter, capable, sober and reliable in every aspect and eac of wom olds a valid driver s licence; b) dismiss immediately any driver wo, wile operating a bus as part of te transportation service, is found to be under te influence of alcool or drugs or is guilty of any improper conduct or uses obscene, blaspemous or offensive language; c) provide, upon request to te scool board a police abstract and/or a certificate of good conduct for any driver designated to operate te scool bus. Te Department and scool boards will continue to strive towards maintaining a safe, efficient and cost effective scool busing service witin te province. Auditor General of Newfoundland and Labrador 217

18 218 Auditor General of Newfoundland and Labrador