February 18, 2020

Phillip Tighe
Chief Financial Officer
Blue Bird Corporation
3920 Arkwright Road
Suite 200
Macon, Georgia 31210

       Re: Blue Bird Corporation
           Registration Statement on Form S-3
           Filed February 11, 2020
           File No. 333-236372

Dear Mr. Tighe:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

       Please contact Thomas Jones at 202-551-3602 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing
cc:    Paul Yousif, Esq.