Blue Bird Corporation

402 Blue Bird Boulevard

Fort Valley, Georgia 31030

September 16, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:     Justin Dobbie, Esq.

Re: Blue Bird Corporation

Registration Statement on Form S-3

File No. 333-206831

Ladies and Gentlemen:

In connection with the above-captioned Registration Statement (the “Registration Statement”), and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Blue Bird Corporation (the “Company”) hereby requests that the above-mentioned Registration Statement be declared effective by the Securities and Exchange Commission (the “Commission”) at 4:00 p.m., Eastern Daylight Time, on Friday, September 18, 2015, or as soon thereafter as practicable.

In connection with the acceleration of the Registration Statement, the Company hereby acknowledges that:

• should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please call Peter H. Ehrenberg of Lowenstein Sandler LLP at 212-204-8697 or Laura R. Kuntz of Lowenstein Sandler LLP at 973-597-2398 to confirm the effectiveness of the Registration Statement or with any questions that you may have.

Very truly yours,

BLUE BIRD CORPORATION

By:    /s/ Paul Yousif

Name: Paul Yousif

Title: Vice President