Pursuant to section 32708 of MAP-21, FMCSA was required to prepare a report that “describes the feasibility, benefits, and costs of establishing a system of certification of public and private schools and of motor carriers and motorcoach operators that provide motorcoach driver training.”  Section 32708 required FMCSA to address what motorcoach operators found most objectionable in a 2007 entry-level driver training (ELDT) NPRM – third-party certification of driver training institutions.  The attached letter-report describes the alternative to third-party certification of motorcoach (and other) driver training recently proposed by FMCSA in the ELDT NPRM.  Because this alternative avoids the cost and administrative complexity of third-party certification of motorcoach training, it effectively resolves the key issue raised by, and satisfies the intent of, section 32708.