Blue Bird Corporation

3920 Arkwright Road, Suite 200

Macon, Georgia 31210

February 19, 2020

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Blue Bird Corporation

Registration Statement on Form S-3

File No. 333-236372

Dear Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, Blue Bird Corporation (the “Company”) hereby requests that the above-referenced Registration Statement (the “Registration Statement”) be declared effective by the Securities and Exchange Commission (the “Commission”) at 5:15 p.m., Eastern Standard Time, on February 21, 2020, or as soon as practicable thereafter.

Please call Peter Ehrenberg of Lowenstein Sandler LLP at (212) 204-8697 to confirm the effectiveness of the Registration Statement or with any questions.

[Signature page follows.]

Very truly yours,

BLUE BIRD CORPORATION

By:/s/ Paul Yousif

Name: Paul Yousif

Title: General Counsel and Corporate Treasurer