BLACKWELL SANDERS PEPER MARTIN LLP
                4801 MAIN STREET SUITE 1000 KANSAS CITY, MO 64112
                   P.O. BOX 219777 KANSAS CITY, MO 64121-6777
                     TEL: (816) 983-8000 FAX: (816) 983-8080
                        WEBSITE: www.blackwellsanders.com

Greg S. Steinberg                                     DIRECT FAX: (816) 983-8080
DIRECT: (816) 983-8387                   E-MAIL: gsteinberg@blackwellsanders.com




                                 August 19, 2005


VIA EDGAR TRANSMISSION

Ms. Beverly A. Singleton
Staff Accountant
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549

     Re:  Collins  Industries,  Inc. - Form 8-K,  filed August 9, 2005
          (File No. 0-32369)

Dear Ms. Singleton:

     On behalf of Collins Industries, Inc. (the "company"), I am writing to
respond to the comments of the staff (the "staff") of the Division of
Corporation Finance of the Securities and Exchange Commission (the "Commission")
set forth in your letter dated August 12, 2005 with respect to the
above-referenced filing (the "comment letter"). This letter is being filed with
the Commission today.

     We are providing a copy of this letter to Timothy P. Davis, Trial Counsel
for the Commission in the Ft. Worth, Texas office, who has been informed of the
workers' compensation investigation discussed in more detail below.

     For ease of reference, each of the staff's comments is reproduced below in
its entirety in bold, followed by the corresponding response.

Item 4.01 of Form 8-K

Reportable Condition:  Material Internal Control Weaknesses

1.   See the fourth paragraph regarding the disclosure of material weaknesses in
     your internal controls. Please provide us with a copy of any letter or
     written communication to and from the former accountants, KPMG LLP, to
     management, the Board of Directors or the audit committee regarding the
     material weaknesses in your internal controls.


  KANSAS CITY, MISSOURI•ST. LOUIS, MISSOURI•OVERLAND PARK, KANSAS•OMAHA, NEBRASKA
SPRINGFIELD, MISSOURI•EDWARDSVILLE, ILLINOIS•WASHINGTON, D.C.•LONDON, UNITED KINGDOM

                           AFFILIATES: LEEDS•MANCHESTER
                        MEMBER OF THE WORLD SERVICES GROUP

Ms. Beverly A. Singleton
August 19, 2005
Page 2


Response: For your information and review, we have enclosed as supplemental
materials copies of all written communications to and from KPMG LLP ("KPMG") to
management, the Board of Directors or the audit committee regarding the material
weaknesses in the company's internal controls:

     •    Audit committee representation letter to KPMG dated June 23, 2005.

     •    Management representation letter to KPMG dated July 28, 2005.

     •    Letter from KPMG to the audit committee dated July 28, 2005 (the
          "SAS-61 Letter").

     •    Letter from KPMG to the audit committee dated July 28, 2005 (the
          "Material Weaknesses Letter").

2.   In detail, describe for us the nature of each material weakness in internal
     controls cited by the former auditors and the amounts involved, if any.
     Also, tell us in what period the reportable event occurred and whether or
     not you restated (or intend to restate) any prior period for any adjustment
     resulting from the reportable event; and if not, why not. Tell us in detail
     the steps you have taken (or plan to take) and procedures you implemented
     (or plan to implement) to correct each reportable event.

Response: The company's material weaknesses identified in the Form 8-K filed
August 9, 2005 were described in detail in its Form 10-K ("Form 10-K") for the
fiscal year ended October 31, 2004, filed on August 3, 2005, and are as follows:

(1) The company did not have effective policies and procedures regarding
management override of controls, and it did not have effective policies and
procedures implementing its Code of Conduct.

As a result of this material weakness, the company did not maintain a control
environment that promoted open and candid communication. In some instances,
certain officers and personnel did not communicate critical information needed
to properly record transactions. These deficiencies result in more than a remote
likelihood that a material misstatement of interim or annual financial
statements could occur and not be detected.

The descriptions referred to below indicate in what period the events related to
this material weakness occurred and the amounts involved, if any. The company
has restated prior periods for the related adjustments, if appropriate.

Ms. Beverly A. Singleton
August 19, 2005
Page 3


     1.   Workers' compensation: Please see (a) the discussion of the second
          material weakness provided in response to Question #2 below; (b)
          footnote (2) to the Description of Adjustments Table in response to
          Question #3 below; and (c) the first bullet point on Page 2 of the
          Material Weaknesses Letter.

     2.   Environmental liabilities: Please see (a) footnote (4) to the
          Description of Adjustments Table in response to Question #3 below and
          (b) the second bullet point on Page 2 of the Material Weaknesses
          Letter.

     3.   Facility expenses: Please see (a) footnote (6) to the Description of
          Adjustments Table in response to Question #3 below and (b) the third
          bullet point on Page 2 of the Material Weaknesses Letter.

     4.   Report of amounts of work-in-progress units: Please see the fourth
          bullet point on Page 2 of the Material Weaknesses Letter. It was not
          necessary to restate any prior period for this item because the report
          is used only by operational personnel and not for financial reporting
          purposes.

To address this material weakness, on March 21, 2005, the company reported that
the chief financial officer and the executive vice president of operations of
the company had retired from the company, effective March 18, 2005. On March 30,
2005, the company reported the appointment of a new chief operating officer of
the company, effective April 1, 2005. On May 12, 2005, the company reported the
hiring of a new chief financial officer of the company. It is believed that
these changes in senior personnel will lead to more open and candid
communication within the company. The Board of Directors will also evaluate and
modify, as appropriate, its policies and procedures implementing the company's
Code of Conduct.

(2) The company had inadequate controls in place to record workers' compensation
reserves in accordance with generally accepted accounting principles.

The company did not have appropriate policies and procedures to ensure the
estimates provided by an independent insurance advisor, which was utilized to
assist in estimating workers' compensation reserves, were appropriate. As a
result, workers' compensation reserves were materially misstated in previously
filed consolidated financial statements. Historical consolidated financial
statements have been restated to correct these errors.

The company discovered issues with workers' compensation claims for injuries
dating back to 1990. The special investigation conducted by the audit committee
revealed that company

Ms. Beverly A. Singleton
August 19, 2005
Page 4


personnel with responsibility for setting reserves did so in an aggressive
manner which caused the third-party administrator adjusters to recommend
reserves at levels lower than they would have otherwise recommended. Personnel
also employed a practice known as stair-stepping reserves for certain claims.
This involves recording reserves initially at an amount lower than the amount
the claim would be expected to settle for and increasing the reserve over time.
In addition, several Florida claims that had existed for an extended period of
time had reserves which had been set artificially low and then increased
periodically to reflect on-going payments to claimants. The accrual of these
amounts in the period that claims were incurred resulted in a charge to retained
earnings for periods prior to October 31, 2001 and a reversal of reserves in
subsequent years to reflect amounts that should already have been recorded.

As a result of the investigation and review of estimated workers' compensation
claims, the company has restated its consolidated financial statements for the
fiscal years ended October 31, 2002 and 2003, and for the quarters ended January
31, 2004 through July 31, 2004. This restatement increased net income by
$242,291, or $.04 per share (diluted), to $1,990,124 for 2002 and by $69,912, or
$.01 per share (diluted), to $1,644,865 for 2003. The beginning balance in
Retained Earnings for 2002 was reduced by $1,443,218 to $8,891,450 to reflect
the additional workers' compensation liability. Previously reported unaudited
net income for the first three quarters of fiscal 2004 increased by $106,734, or
$.02 per share (diluted), to $1,530,207. Net income reflected in the unaudited
consolidated financial statement information for the year ended October 31, 2004
contained in the November 22, 2004 Current Report on Form 8-K decreased by
$153,579. The opening equity as of November 1, 2001 has been restated by
$1,443,218.

On May 12, 2005, the company announced that its audit committee had recommended
revised procedures for establishing workers' compensation reserves. Revised
procedures were put in place to help ensure reserve recommendations made by the
Third Party Administrator ("TPA") are recorded. Procedures also prohibit
inappropriate influence by management in the determination of the TPA's
recommended reserve amounts. The revised procedures require increased accounting
oversight to help insure reserves are recorded in accordance with generally
accepted accounting principles. The Board of Directors approved the
recommendation. Effective July 1, 2005, the company purchased guaranteed cost
workers' compensation insurance for the states in which it had previously
self-insured. The company continues to be self-insured in certain states for
workers' compensation claims incurred prior to July 1, 2005.

The Company's General Plans and Procedures to Address Both Material Weaknesses

In addition to the steps taken and procedures implemented by the company as set
forth above, now that the 2004 audit process is complete, the audit committee is
scheduled to meet August 22,

Ms. Beverly A. Singleton
August 19, 2005
Page 5


2005, and the Board of Directors is scheduled to meet August 23, 2005, to
identify and address the steps the company will take and the procedures the
company will implement to correct each material weakness. Any steps and
procedures adopted pursuant to these meetings will be provided supplementally to
the staff under separate cover.

The company contemplates undertaking a thorough review of its internal controls
as part of the company's preparation for compliance with the requirements under
Section 404 of the Sarbanes-Oxley Act of 2002 and the company is using this
review to further assist in identifying and correcting any other control
deficiencies, if any. At this time, the company has not completed its review of
the existing controls and their effectiveness.

The management and the Board are committed to correcting the material weaknesses
and will take all necessary action to accomplish this. The company will also
further develop and enhance its internal control policies, procedures, systems
and staff to allow it to mitigate the risk that material accounting errors might
go undetected and be included in its consolidated financial statements.

3.   Please provide us with a schedule of your fiscal year end October 31, 2004
     fourth quarter adjustments recorded in connection with or as a result of
     the audit. Clearly explain the reason for each adjustment. For each
     adjustment, show us the impact on pre-tax net loss. Quantify the net effect
     of all adjustments on pre-tax net income (loss). Also, tell us if any of
     the adjustments relate to a prior period. Explain in detail why you believe
     the timing of each adjustment is appropriate.

Response: The information contained in the Description of Adjustments Table and
related footnotes is disclosed in Item 7 of the company's Form 10-K. The table
identifies the adjustments made to previously-released consolidated financial
statements. Each adjustment described below was recorded in the period in which
the event giving rise to the adjustment occurred. The company also adjusted
estimated accruals for actual values for certain items during the fourth quarter
of 2004. In addition, the financial statements were adjusted for certain events
which occurred subsequent to the balance sheet date but prior to issuance of the
financial statements, which met the criteria set forth in AU 560.

Ms. Beverly A. Singleton
August 19, 2005
Page 6


                        Description of Adjustments Table


Description of Adjustments                                                   Periods Prior
($ In thousands)                                                                   To
                                                 2004(1)      2003    2002        2002
-------------------------------------------------------------------------------------------
Workers' Compensation Reserve Adjustments (2)   $  612      $  24    $ 411    $ (2,359)
Workers' Compensation Premium Increase (3)         (37)         -        -           -
Environmental Reserve Accrual (4)                  (59)         -        -           -
Uncollectible Rebates (5)                          (55)        (6)       -           -
Other Accrued Expenses (6)                        (605)        82      (19)        (14)
-------------------------------------------------------------------------------------------
     Total pre-tax impact                       $ (144)     $ 100    $ 392    $ (2,373)
     Income tax (7)                                (10)       (30)    (150)        930
-------------------------------------------------------------------------------------------
Total Net Income Impact                         $ (154)     $  70    $ 242    $ (1,443)
-------------------------------------------------------------------------------------------


(1)  The 2004 amounts have been revised by the company for the quarters ended
     January 31, 2004, April 30, 2004 and July 30, 2004 and financial statement
     information for the year ended October 31, 2004 compared to what was
     previously furnished in the November 22, 2004 Current Report on Form 8-K.

(2)  Adjustments to workers' compensation liability reserves which had not
     previously been recorded. These adjustments are reflected in cost of sales
     on the income statement and accrued expenses and other current liabilities
     on the balance sheet. Adjustments in 2004, 2003 and 2002 also reflect
     reversal of expense recorded in those years which should have been recorded
     in prior periods.

     Consolidated Statements of Income and Comprehensive Income: Adjustment
     decreased (increased) cost of sales by the amounts set forth in this table.

     Consolidated Balance Sheets: Adjustment increased accrued expenses and
     other current liabilities by $1,312, $1,923 and $1,948, at October 31,
     2004, 2003 and 2002, respectively.

(3)  In January 2005 the company received a notice that its State of Ohio
     workers' compensation premium attributable to fiscal year 2004 would
     increase by $37.

     Consolidated Statements of Income and Comprehensive Income: Adjustment
     increased cost of sales by the amounts set forth in this table.

     Consolidated Balance Sheets: At October 31, 2004, adjustment increased
     accounts payable by $37.

(4)  In February 2005, the company received notice from its counsel that amounts
     previously recorded for potential environmental liabilities were
     understated. Such amounts were increased by $59. This adjustment is
     reflected in cost of sales on the income statement and accounts payable on
     the balance sheet.

     Consolidated Statements of Income and Comprehensive Income: Adjustment
     increased cost of sales by the amounts set forth in this table.

     Consolidated Balance Sheets: At October 31, 2004, adjustment increased
     accounts payable by $59.

Ms. Beverly A. Singleton
August 19, 2005
Page 7


(5)  Relates to corrections to the estimate of rebate collectibility at October
     31, 2004.

     Consolidated Statements of Income and Comprehensive Income: Adjustment
     increased cost of sales by $55 in 2004 and $6 in 2003.

     Consolidated Balance Sheets: At October 31, 2004 and 2003, adjustment
     decreased receivables by $61 and $6, respectively.

(6)  The 2004 items relate to several miscellaneous adjustments primarily
     revising estimated accruals to actual expense. The 2004 items include legal
     reserve accruals ($340), employee medical expense accruals ($200), facility
     expenses ($10), product returns ($17), product concessions expense ($10),
     and reversal of product liability expense ($85) partially offset by lower
     actual employee bonuses ($34), and lower audit fees ($25).

     Consolidated Statements of Income and Comprehensive Income: Adjustments
     decreased sales by $13, increased cost of sales by $400 and increased
     selling, general and administrative expenses by $191.

     Consolidated Balance Sheets: At October 31, 2004, adjustment increased
     accrued expense and other current liabilities by $216, increased accounts
     payable by $295, increased inventories by $11 and decreased receivables by
     $56. An additional entry related to subsequent payments for goods and
     service made in 2005 related to 2004 increased inventories and accounts
     payable by $113, respectively.

     The 2003 items primarily include corrections to facility expenses ($35),
     product concessions ($14) offset by lower product liability expense ($85),
     lower actual employee bonuses ($3), and lower accounts receivable allowance
     expense ($43).

     Consolidated Statements of Income and Comprehensive Income: Adjustments
     decrease sales by $29, increased cost of sales by $20 and decreased
     selling, general and administrative expenses by $132 in 2003.

     Consolidated Balance Sheets: At October 31, 2003, adjustment decreased
     accrued expense and other current liabilities by $111, increased accounts
     payable by $35, decreased receivables by $53 and increased inventories by
     $26.

     The 2002 items primarily include corrections to increase accounts
     receivable allowance expense ($43) partially offset by lower actual
     employee bonuses ($22), and lower product concessions expense ($2).

     Consolidated Statements of Income and Comprehensive Income: Adjustments
     increased sales by $4, increased cost of sales by $2 and increased selling,
     general and administrative expense by $21 in 2002.

     Consolidated Balance Sheets: At October 31, 2002, adjustment decreased
     receivables by $56, and decreased accrued expense and other current
     liabilities by $23.

     The adjustment to periods prior to 2002 is increased product concessions
     expense by $14 and is reflected as a $28 decrease to sales and a $14
     decrease to cost of sales in the Consolidated Statements of Income and
     Comprehensive Income in 2001. Receivables decreased $28 and inventories
     increased $14 in the Consolidated Balances Sheet as of October 31, 2001.

     Amounts in 2004, 2003 and 2002 also reflect adjustments for expenses
     recorded in those years which

Ms. Beverly A. Singleton
August 19, 2005
Page 8


     should have been recorded in prior periods.

(7)  Relates to approximately $40 of income tax benefit related to the
     adjustments described above, offset by $50 of additional estimated income
     tax expense in 2004. Tax amounts for 2003 and 2002 represent the tax effect
     due to the adjustments.

     Consolidated Statements of Income and Comprehensive Income: Adjustment
     increased income taxes by the amount set forth in this table.

     Consolidated Balance Sheets: At October 31, 2004, adjustment increased
     accounts payable by $50.

     The cumulative effect of all entries increased prepaid expenses and other
     current assets by $790, $750 and $780 for the years ended October 31, 2004,
     2003 and 2002, respectively.

                                    * * * * *

This restatement increased net income by $242,291, or $.04 per share (diluted),
to $1,990,124 for 2002 and $69,912, or $.01 per share (diluted), to $1,644,865
for 2003. The balance in Retained Earnings as previously reported at October 31,
2001 was reduced by $1,443,218 to $8,891,450 to reflect the additional workers'
compensation reserves which should have been recorded in earlier periods.
Previously reported unaudited net income for the first three quarters of fiscal
2004 increased by $106,734, or $.02 per share (diluted), to $1,530,207. Net
income reflected in the unaudited consolidated financial statement information
for the year ended October 31, 2004 furnished in the November 22, 2004 Current
Report on Form 8-K decreased by $153,579. The opening equity as of November 1,
2001 has been restated by $1,443,218. All applicable financial information
contained in the Report on Form 10-K for the fiscal year ended October 31, 2004,
gives effect to these restatements.

                                    * * * * *

     In accordance with your request in the comment letter, we have included a
statement from the company acknowledging that:

          •    the company is responsible for the adequacy and accuracy of the
               disclosure in the filing;

          •    staff comments or changes to disclosure in response to staff
               comments do not foreclose the Commission from taking any action
               with respect to the filing; and

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

Ms. Beverly A. Singleton
August 19, 2005
Page 9


     If you have any questions regarding any of the responses, please feel free
to call me at 816-983-8387.



                                       Very truly yours,

                                       BLACKWELL SANDERS PEPER MARTIN LLP



                                       By:  /s/ Gregory S. Steinberg
                                          --------------------------------------
                                            Gregory S. Steinberg


Enclosures

cc:  Timothy P. Davis, Securities and Exchange Commission

                            Collins Industries, Inc.
                15 Compound Drive Hutchinson, Kansas 67502-4349
                                 (620) 663-5551
                _______________________________________________

August 19, 2005


Via EDGAR Transmission
Ms. Beverly A. Singleton
Staff Accountant
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549

     Re:  Collins  Industries,  Inc. - Form 8-K,  filed August 9, 2005
          (File No. 0-32369)

Dear Ms. Singleton:

     In  accordance  with your request in your letter dated August 12, 2005 with
respect to the above-referenced filing, we acknowledge that:


     •    the  company is  responsible  for the  adequacy  and  accuracy  of the
          disclosure in the filings;

     •    staff  comments or changes to disclosure in response to staff comments
          do not foreclose the Securities and Exchange Commission ("Commission")
          from taking any action with respect to the filings; and

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


                                       Very truly yours,


                                       COLLINS INDUSTRIES, INC.



                                       By:  /s/ Cletus Glasener
                                          --------------------------------------
                                            Cletus Glasener, Vice President of
                                            Finance and Chief Financial Officer

                            Collins Industries, Inc.
                15 Compound Drive Hutchinson, Kansas 67502-4349
                                 (620) 663-5551
                _______________________________________________

KPMG LLP
1000 Walnut Street
Suite 1000
Kansas City, Mo  64106-2170


June 23, 2005


Ladies and Gentlemen:

We are providing this letter in connection with your audits of the  consolidated
balance sheets of Collins Industries, Inc., as of October 21, 2004 and 2003, and
the  related  consolidated   statements  of  earnings,   retained  earnings  and
comprehensive  income,  and cash  flows for each of the years in the  three-year
period ended  October 3l, 2004,  for the purpose of  expressing an opinion as to
whether these consolidated  financial statements present fairly, in all material
respects, the financial position,  results of operations,  and cash flows of the
Company in  conformity  with  accounting  principles  generally  accepted in the
United States of America.

For purposes of your audit noted above,  we confirm that we are not aware of any
information  withheld  from  KPMG LLP that the Audit  Committee  of the Board of
Directors has obtained regarding  violations or possible  violations or possible
violations of laws or  regulations  that may have been committed by the Company,
or any of its agents or employees.

The Audit Committee of the Company also engaged Seigfried, Bingham, Levy, Selzer
& Gee (Seigfried) to conduct an investigation into the practices employed by the
Company in  determining  liability  reserves  under its self-  insured  workers'
compensation  plan for  employees  in  Kansas  and  Florida  and  whether  those
practices,  as implemented,  violated any applicable federal, state or local law
or regulation,  hereafter referred to as the  "Investigation".  We have directed
the Company and  Seigfried to provide you with access to all relevant  documents
and facts obtained and/or prepared in connection with the Investigation. We have
been  advised by the Company and  Seigfried  that they have  complied  with such
directions.  Accordingly, and for the purposes of your audit of the consolidated
balance  sheet  of  the  Company  as  of  October  31,  2004,  and  the  related
consolidated statements of results of operations,  shareholders' equity and cash
flow for the year  then  ended,  we  confirm  the  following  to the best of our
knowledge and belief:

         1.       You lave been provided  with access to all relevant  documents
                  and  information  obtained or prepared in connection  with the
                  Investigation.

         2.       The Investigation is complete.

         3.       The   Investigation  has  provided  us  with  all  information
                  necessary for us to determine that it is  appropriate  for the
                  Company to include the financial  statements referred to above
                  in filings with the Securities and Exchange Commission.

         4.       Based on the  findings  of the  Investigation,  the  Company's
                  Board of Directors and management  have taken,  or are taking,
                  or are  currently  planning  to take  timely  and  appropriate
                  remedial action where necessary.

         5.       We  confirm  that all  relevant  information  relating  to the
                  ongoing informal investigation initiated by the Securities and
                  Exchange  Commission  has been  disclosed by management to the
                  Audit  Committee,  to the  investigating  team, and to you. We
                  also confirm that all matters that have been

                            Collins Industries, Inc.
                15 Compound Drive Hutchinson, Kansas 67502-4349
                                 (620) 663-5551
                _______________________________________________

Page 2


                  identified  in the  investigation  that require  disclosure or
                  modifications to the Companies' financial statements as of and
                  for the year ended October 31, 2004 have been disclosed.

         6.       There  are no other  possible  illegal  acts  which  the audit
                  committee has become aware of that require investigation.



/s/ William R. Patterson
--------------------------------        ----------------------------------------
William R. Patterson
Chairman of the Audit Committee


/s/ Arch G. Gothard III
--------------------------------        ----------------------------------------
Arch G. Gothard III
Audit Committee

                            Collins Industries, Inc.
                15 Compound Drive Hutchinson, Kansas 67502-4349
                                 (620) 663-5551
                _______________________________________________

Page 3



/s/ Don S. Peters
--------------------------------        ----------------------------------------
Don S. Peters
Audit Committee

                            Collins Industries, Inc.
                15 Compound Drive Hutchinson, Kansas 67502-4349
                                 (620) 663-5551
                _______________________________________________

KPMG LLP
1000 Walnut Street
Suite 1000
Kansas City, Mo 64106-2170


July 28, 2005


Ladies and Gentlemen:

We are providing this letter in connection with your audits of the  consolidated
balance sheets of Collins  Industries,  Inc. (the "Company"),  as of October 31,
2004 and 2003,  and the related  consolidated  statements of earnings,  retained
earnings and comprehensive  income,  and cash flows for each of the years in the
three-year  period ended  October 31,  2004,  for the purpose of  expressing  an
opinion as to whether these consolidated financial statements present fairly, in
all material respects, the financial position,  results of operations,  and cash
flows of the Company in conformity with accounting principles generally accepted
in the United States of America.  In addition,  we are providing  this letter in
connection with your review of the consolidated interim financial information of
the Company as of January  31,  2005 and April 30, 2005 and for the  three-month
and six-month periods ended for the purpose of determining  whether any materia1
modifications should be made to the consolidated  interim financial  information
for them to conform  with U.S.  generally  accepted  accounting  principles.  We
confirm that we are  responsible for the fair  presentation of the  consolidated
interim financial information in the aforementioned documents in conformity with
U.S. generally accepted accounting principles.

Certain representations in this letter are described as being limited to matters
that are material.  Items are considered  material,  regardless of size, if they
involve an omission or misstatement of accounting information that, in the light
of  surrounding  circumstances,  makes  it  probable  that  the  judgment  of  a
reasonable  person relying on that information would be changed or influenced by
the omission or misstatement.

We  confirm,   to  the  best  of  our  knowledge   and  belief,   the  following
representations made to you during your audits:

1.   The  consolidated   financial  statements  referred  to  above  are  fairly
     presented in conformity with accounting  principles  generally  accepted in
     the United States of America.

2.   We have made available to you:

     a.   All financial records and related data.

     b.   All minutes of the meetings of stockholders, directors, and committees
          of  directors,  or summaries  of actions of recent  meetings for which
          minutes  have not yet been  prepared.  All  material  conclusions  and
          findings of the special investigation have been communicated to you.

3.   Except as disclosed to you in writing, there have been no:

     a.   Facts and circumstances that have resulted in communications  from any
          of the Company's external legal counsel to any member of the Company's
          management  reporting  evidence of a material  violation of securities
          law or breach of fiduciary duty or similar violation by the Company or
          any agent thereof.

     b.   False  statements  affecting  the  Company's   consolidated  financial
          statements made to the Company's internal auditors,  or other auditors
          who have audited entities under our control upon whose work you may be
          relying in connection with your audits.

     c.   Communications from regulatory agencies concerning noncompliance with,
          or deficiencies in, financial reporting practices.

     d.   Violations  or  possible  violations  of  laws or  regulations,  whose
          effects  should  be  considered  for  disclosure  in the  consolidated
          financial statements or as a basis for recording a loss contingency.

4.   There are no:

     a.   Unasserted  claims or assessments that our lawyers have advised us are
          probable  of  assertion  and  must be  disclosed  in  accordance  with
          Statement of Financial  Accounting  Standards (SFAS) No. 5, Accounting
          for Contingencies.

     b.   Other liabilities or gain or loss  contingencies  that are required to
          be  accrued  or   disclosed  by  SFAS  No.  5,  which  have  not  been
          appropriately disclosed.

     c.   Material  transactions  that have not been  properly  recorded  in the
          accounting records underlying the consolidated financial statements.

     d.   Events that have  occurred  subsequent  to the balance  sheet date and
          through the date of this letter that would  require  adjustment  to or
          disclosure in the consolidated financial statements that have not been
          appropriately disclosed.

5.   In "Item 9A - Controls and  Procedures" of the 2004 Form 10-K, we disclosed
     to you all significant  deficiencies in the design or operation of internal
     controls,  of which we are aware and we believe could adversely  affect the
     Companies ability to record,  process,  summarize and report financial data
     and  identified  all  material  weaknesses  in internal  controls.  We have
     disclosed  in Item 9A the  material  control  weaknesses  identified  as of
     October 31, 2004. We interpret  "significant  deficiencies in the design or
     operation  of internal  controls"  to be  consistent  with the concept of a
     "reportable condition," defined under standards established by the American
     Institute  of  Certified  Public  Accountants.   Such  standards  define  a
     "reportable  condition"  as a  significant  deficiency  in  the  design  or
     operation  of internal  control  that could  adversely  affect the entity's
     ability to initiate,  record, process, and report financial data consistent
     with  the  assertions  of  management  in  the  financial  statements.   We
     understand  that the term  "material  weakness  in  internal  control" is a
     reportable  condition  for which the  design  or  operation  of one or more
     internal  control  components does not reduce to a relatively low level the
     risk that errors or fraud in amounts  that could be material in relation to
     the  financial  statements  may occur and not be  detected  within a timely
     period by  employees  in the normal  course of  performing  their  assigned
     functions.

6.   We acknowledge  our  responsibility  for the design and  implementation  of
     programs and controls to prevent and detect fraud.  We understand  that the
     term  "fraud"  includes  misstatements  arising from  fraudulent  financial
     reporting  and  misstatements  arising  from  misappropriation  of  assets.
     Misstatements  arising from fraudulent  financial reporting are intentional
     misstatements,   or  omissions  of  amounts  or  disclosures  in  financial
     statements to deceive financial statement users. Misstatements arising from
     misappropriation  of assets  involve the theft of an entity's  assets where
     the effect of the theft causes the consolidated financial statements not to
     be presented in conformity with accounting principles generally accepted in
     the United States of America.

7.   Noting  point eight  below,  we have no knowledge of any fraud or suspected
     fraud affecting the entity involving:

     a.   Management,


                                       2

     b.   Employees who have significant roles in internal control, or

     c.   Others   where  the  fraud  could  have  a  material   effect  on  the
          consolidated financial statements.

8.   We have  discussed  with you the matters set forth below.  Excepting  those
     matters,  and without  characterizing  them,  we have no  knowledge  of any
     allegations of fraud or suspected  fraud  affecting the entity  received in
     communications  from employees,  former  employees,  analysts,  regulators,
     short sellers, or others. We have discussed:

     a.   Results  of the  special  investigation  performed  of  the  practices
          employed by the Company in determining  liabilities reserves under its
          self-insured  workers'  compensation  plan for employees in Kansas and
          Florida (the "Special Investigation") under the direction of the audit
          committee.

     b.   Inventory reporting at Mid-Bus by a plant manager who was subsequently
          terminated.

     c.   Allegations by regulators  regarding  documentation  submitted to Ohio
          EPA.

     d.   Invoices  related to work  performed by an  electrical  contractor  at
          Wheeled Coach Kansas that were not originally recorded but should have
          been recorded at October 31, 2004.

9.   The  Company  has no plans or  intentions  that may  materially  affect the
     carrying value or classification of assets and liabilities.

10.  We believe that there are no material  unrecoverable  amounts classified as
     assets in the consolidated financial statements.

11.  The Company has satisfactory  title to all material owned assets, and there
     are no liens or encumbrances on such assets nor has any material asset been
     pledged as collateral, unless disclosed.

12.  The Company has complied with all aspects of  contractual  agreements  that
     would have a material effect on the  consolidated  financial  statements in
     the event of noncompliance.

13.  The following have been properly  recorded or disclosed in the consolidated
     financial statements:

     a.   Related  party  transactions   including  sales,   purchases,   loans,
          transfers,  leasing  arrangements,   guarantees,  ongoing  contractual
          commitments and amounts receivable from or payable to related parties.
          We understand  that the term  "related  party" refers to affiliates of
          the  enterprise;  entities for which  investments are accounted for by
          the  equity  method  by the  enterprise;  trusts  for the  benefit  of
          employees,  such as pension and profit sharing trusts that are managed
          by or under the  trusteeship  of management;  principal  owners of the
          enterprise;  its  management;  members of the  immediate  families  of
          principal  owners  of the  enterprise  and its  management;  and other
          parties with which the  enterprise  may deal if one party  controls or
          can  significantly  influence the management or operating  policies of
          the other to an extent that one of the  transacting  parties  might be
          prevented  from fully  pursuing  its own separate  interests.  Another
          party also is a related  party if it can  significantly  influence the
          management or operating  policies of the transacting  parties or if it
          has an ownership  interest in one of the  transacting  parties and can
          significantly influence the other to an extent that one or more of the
          transacting  parties  might be prevented  from fully  pursuing its own
          separate interests.

     b.   Guarantees,  whether  written  or oral,  under  which the  Company  is
          contingently liable, including guarantee contracts and indemnification
          agreements   pursuant  to  FASB  Interpretation  No.  45,  Guarantor's
          Accounting  and  Disclosure  Requirements  for  Guarantees,  Including
          Indirect Guarantees of Indebtedness of Others.


                                       3

     c.   Significant estimates and material  concentrations known to management
          that are  required  to be  disclosed  in  accordance  with the AICPA's
          Statement of Position  (SOP) 94-6,  Disclosure of Certain  Significant
          Risk and  Uncertainties.  Significant  estimates  are estimates at the
          balance  sheet date,  which could  change  materially  within the next
          year. Concentrations refer to volumes of business, revenues, available
          sources of supply,  or  markets  or  geographic  areas for which it is
          reasonably  possible that events could occur which would significantly
          disrupt normal finances within the next year.  Concentrations  include
          material   sources   of   financing,   including   off-balance   sheet
          arrangements and  transactions  with  unconsolidated,  limited purpose
          entities,  and contingencies  inherent in the  arrangements,  that are
          reasonably  likely to affect the continued  availability  of liquidity
          and financing.

     d.   Off-balance sheet activities,  including  accounting policies relating
          to non-consolidation and revenue recognition.  Specifically, for those
          off-balance  sheet  activities  in which the  Company  is a sponsor or
          transferor,  the majority owners of the off-balance  sheet vehicle are
          independent  third parties who have made and  maintained a substantive
          capital  investment  in the  vehicle,  control  the  vehicle  and have
          substantive risks and rewards of the assets of the vehicle,  including
          residuals.

     e.   Variable  interest  entities,  and significant  variable  interests in
          variable  interest  entities  in which the  Company  is not deemed the
          primary  beneficiary,  pursuant to either FASB  Interpretation No. 46,
          Consolidation  of  Variable   Interest  Entities  (FIN  46),  or  FASB
          Interpretation  No.  46  (revised  December  2003),  Consolidation  of
          Variable Interest Entities (FIN 46R).

     f.   Changes in accounting principle affecting consistency.

     g.   Results  of  the  Special   Investigation   and  related   restatement
          adjustments and disclosures.

14.  Receivables  reported in the consolidated  financia1  statements  represent
     valid  claims  against  debtors  for sales or other  charges  arising on or
     before the balance sheet date and have been appropriately  reduced to their
     estimated net realizable value.

15.  Provision, when material, has been made for:

     a.   Losses to be sustained  in the  fulfillment  of, or from  inability to
          fulfill, any sales commitments.

     b.   Losses  to be  sustained  as a  result  of  purchase  commitments  for
          inventory  quantities in excess of normal requirements or at prices in
          excess of the prevailing market prices.

     c.   Losses  to be  sustained  as a result  of the  reduction  of excess or
          obsolete inventories to their estimated net realizable value.

     d.   Losses to be sustained as a result of other-than-temporary declines in
          the fair value of investments.

16.  The  Company  has  not,   directly  or  indirectly,   including  through  a
     subsidiary,  extended or maintained  credit,  arranged for the extension of
     credit, or renewed an extension of credit in the form of a personal loan to
     or for any  director or  executive  officer of the  Company (or  equivalent
     thereof) that is considered  prohibited  under Section 402 of the Sarbanes-
     Oxley Act of 2002.

17.  The Company is  responsible  for  determining  the fair value of  financial
     instruments  as required by SFAS No. 107,  Disclosures  about Fair Value of
     Financial  instruments.  The amounts disclosed represent the Company's best
     estimate of fair value of  financial  instruments  required to be disclosed
     under the  Statement  (and  other  assets  or  liabilities,  if  separately
     disclosed).  The Company  also has  disclosed  the methods and  significant
     assumptions used to estimate the fair value of its financial instruments.

18.  The calculations of current and deferred tax expense  (benefit) and related
     current and deferred tax assets and liabilities  have been determined based
     on appropriate  provisions of applicable  enacted tax laws and


                                       4

     regulations.  Management  believes  the net defend tax asset at October 31,
     2004 is realizable and that there is no need for a valuation allowance.

19.  The  Company's  reporting  units  have  been  appropriately  identified  in
     accordance  with SFAS No. 142,  Goodwill and Other  Intangible  Assets.  No
     provision is required for any impairment  losses related to goodwill and/or
     non-amortizable intangible assets.

20.  The Company has accounted  for its  derivatives  and hedging  activities in
     accordance  with SFAS No. 133,  Accounting for Derivative  Instruments  and
     Hedging  Activities,  and SFAS No. 138,  Accounting for Certain  Derivative
     Instruments and Certain Hedging Activities,  an Amendment of FASB Statement
     No. 133, including the requirement for contemporaneous documentation of the
     hedging  relationship  and the  Company's  risk  management  objective  and
     strategy  for  entering  into the  hedge as well as  initial  and  periodic
     effectiveness  assessments.  The  estimate  of  fair  value  of  derivative
     instruments  is in  compliance  with  EITF  Issue  02-03,  Recognition  and
     Reporting  Gains and  Losses on Energy  Trading  Contracts,  including  the
     propriety of  recognized  gains and losses at  inception of the  derivative
     instruments when using internal valuation techniques.

21.  The unaudited interim financial information,  accompanying the consolidated
     financial  statements  for the  2004 and 2003  three-month  periods  ending
     January 31,  April 30, July 31, and October 31, and the  unaudited  interim
     financial information as of January 31, 2005 and April 30, 2005 and for the
     thee-month and six-month periods ended, have been prepared and presented in
     conformity  with  accounting  principles  generally  accepted in the United
     States of America applicable to interim financial information and with Item
     302(a) of Regulation  S-K. The  accounting  principles  used to prepare the
     unaudited interim  financial  information are consistent with those used to
     prepare  the  audited  consolidated  financial  statements.  The  quarterly
     results for each period reflect the  restatement  adjustments  required for
     fair presentation.

22.  The Company's  reportable  segments have been appropriately  identified and
     the  related  segment  and  enterprise-wide  disclosures  have been made in
     accordance with SFAS No. 131,  Disclosures  about Segments of an Enterprise
     and Related Infomation.

23.  Based on projections,  we anticipate the Company will be in compliance with
     all covenants  related to financing  arrangements  during fiscal year 2005,
     except  for the late  filing of the 2004  Annual  Report  for which we have
     obtained a waiver and discussed with you.

24.  We believe  that the  actuarial  assumptions  and  methods  used to measure
     workers'  compensation  liabilities  and  costs  for  financial  accounting
     purposes are appropriate in the  circumstances.  The restated  reserves for
     workers'  compensation  claims represent  management's best estimate of the
     ultimate liability for each claim.

25.  Provision  has been  made  for any  material  loss  that is  probable  from
     environmental remediation liabilities associated with the states of Kansas,
     Texas,  Ohio,  Florida  and  Oklahoma.  We believe  that such  estimate  is
     reasonable  based on available  information  and that the  liabilities  and
     related loss  contingencies and the expected outcome of uncertainties  have
     been  adequately   disclosed  in  the  Company's   consolidated   financial
     statements.

26.  The $152,292 accrued  liability related to the joint strength failure cited
     by NHTSA at Mid-Bus is management's best estimate of the cost to repair the
     units projected to be submitted under recall at October 31, 2004.

27.  All sales transactions  entered into by the Company are final and there are
     no side agreements with  customers,  or other terms in effect,  which allow
     for the return of merchandise, except for defectiveness or other conditions
     covered by the usual and customary warranties, other than the GE floor plan
     agreement.  Units  sold  and  held  at  Company  facilities  meet  all  the
     requirements of SAB 104 and related interpretations.


                                       5

28.  We believe any future losses under the repurchase agreement with GE related
     to floor plan financing for dealers will not have a material adverse effect
     on the Company's financial position or results of operations. The Company's
     repurchase  obligation  under these agreements is limited to vehicles which
     are in new condition and as to which the dealer still holds title.

29.  Revenue from separately priced extended warranty  contracts is deferred and
     recognized in income on a  straight-line  basis over the contract period as
     sufficient historical evidence does not exist which indicate that the costs
     of  performing  services  under the  contract  are incurred on other than a
     straight-line basis.

30.  We believe the net book value of the Oklahoma land and facility is equal to
     or less than the fair value.

31.  Pursuant to  provisions  of the  Securities  Exchange  Act of 1934,  we are
     responsible  for  establishing  and  maintaining  disclosure  controls  and
     procedures for the Company, and have:

     a.   Designed  such  disclosure  controls  and  procedures,  or caused such
          disclosure   controls  and   procedures  to  be  designed   under  our
          supervision,  to ensure  that  material  information  relating  to the
          registrant,  including its consolidated subsidiaries, is made known to
          us by others within those entities,  particularly during the period in
          which the  Company's  financial  statements  and annual report on Form
          10-K for the fiscal year ended October 31, 2004 are being prepared;

     b.   Designed such internal  control over  financial  reporting,  or caused
          such internal  control over  financial  reporting to be designed under
          our  supervision,   to  provide  reasonable  assurance  regarding  the
          reliability  of financial  reporting and the  preparation of financial
          statements for external purposes in accordance with generally accepted
          accounting principles;

     c.   Evaluated the effectiveness of the Company's  disclosure  controls and
          procedures  and presented in the Company's  annual report on Form 10-K
          for the fiscal year ended October 31, 2004 our  conclusions  about the
          effectiveness of the disclosure controls and procedures, as of the end
          of the period covered by the Company's  annual report on Form 10-K for
          the fiscal year ended October 31, 2004, based on such evaluation; and

     d.   Disclosed in the  Company's  annual report on Form 10-K for the fiscal
          year ended  October 31, 2004 any change in the  registrant's  internal
          control over financial  reporting  that occurred  during the Company's
          most recent fiscal quarter (the registrant's  fourth fiscal quarter in
          the case of an annual  report)  that has  materially  affected,  or is
          reasonably likely to materially affect, the Company's internal control
          over financial reporting.

32.  Except  as set  forth in point #5  above,  pursuant  to  provisions  of the
     Securities  Exchange  Act of 1934,  there have been no changes in  internal
     control over financial  reporting  that occurred  during the Company's most
     recent fiscal quarter ended October 31, 2004,  that has a material  effect,
     or is reasonably likely to have a material effect, on internal control over
     financial reporting.

33.  As of the date of this letter,  the Company is not past due with respect to
     any portion of its assessed  Public Company  Accounting  Oversight Board or
     FASB accounting support fees.

34.  The  delay in  filing  audited  financial  statements  for the year  ending
     October 31, 2004 constituted a covenant violation pursuant to the Company's
     Loan and Security Agreement.  The Company obtained a waiver from its lender
     regarding   this  event.   The  Company  has  not   received   any  default
     notifications.  Management  believes all covenant  violations and events of
     non-compliance have been remedied with the filing of its delinquent reports
     on Forms 10-K and 10-Q concurrently.

35.  Management has  appropriately  considered and disclosed the key findings of
     the Special  Investigation and believes the restated  financial  statements
     reflect the  adjustments  needed to fairly present the Company's  operating
     results and financial condition for all periods presented.


                                       6

Further,  we confirm that we are  responsible  for the fair  presentation in the
consolidated financial statements of financial position,  results of operations,
and cash flows in conformity with accounting  principles  generally  accepted in
the United States of America.

Very truly yours,

Collins Industries, Inc. and Subsidiaries


                                       7

/s/ Donald Lynn Collins                /s/ Cletus Glasener
--------------------------------       --------------------------------
Donald Lynn Collins                    Cletus Glasener
President and CEO                      Chief Financial Officer


                                       8

          KPMG LLP                                 Telephone     816 802 5200
          Suite 1000                               Fax           816 802 5400
          1000 Walnut Street                       Internet      www.us.kpmg.com
          Kansas City, MO 64106-2162


July 28, 2005


Mr. William R. Patterson
Mr. Arch G. Gothard, III
Mr. Don S. Petters
Audit Committee
Collins Industries
180 State Street
Southlake, Texas 76092

Gentlemen:

We have audited the  consolidated  financial  statements of Collins  Industries,
Inc.  (Collins or the  Company) for the year ended  October 31,  2004,  and have
issued our report  thereon under date of July 28, 2005.  Under our  professional
standards,  we are  providing you with the attached  information  related to the
conduct of our audits.

Our Responsibility Under Professional Standards

We have a  responsibility  to conduct our audit of the  financial  statements in
accordance with professional standards. In carrying out this responsibility,  we
planned and performed the audit to obtain reasonable assurance about whether the
financial statements are free of material misstatement,  whether caused by error
or fraud.  Because of the nature of audit  evidence and the  characteristics  of
fraud,  we are to obtain  reasonable,  not  absolute,  assurance  that  material
misstatements  are detected.  We have no  responsibility to plan and perform the
audit to obtain reasonable assurance that misstatements, whether caused by error
or fraud, that are not material to the financial statements are detected.

In addition,  in planning and performing our audit of the financial  statements,
we considered internal control in order to determine our auditing procedures for
the purpose of expressing our opinion on the financial  statements.  An audit of
the  financial  statements  does not  include  examining  the  effectiveness  of
internal control and does not provide assurance on internal control.

Accounting Policies

Significant Accounting Policies and Unusual Transactions

The significant  accounting policies used by the Company are described in Note 1
to the consolidated financial statements.

The  special  investigation  and  results  are  described  in  Note  11  of  the
consolidated  financial  statements.  The debt covenant  violation,  waiver, and
status are described in Note 3 of the  consolidated  financial  statements.  The
control  issues noted during out  examination,  including  two material  control
weaknesses, are described in item 9a in the Form 10-K for financial year 2004.

KPMG
Audit Committee
Collins Industries
July 28, 2005
Page 2


Critical Accounting Policies and Practices

The critical  accounting policies and practices used by the Company in preparing
its  consolidated   financial   statements  are  as  described  in  Management's
Discussion and Analysis.  These policies and practices are considered  both most
important to the portrayal of the Company's  financial  condition and results of
operations,  and require  management's  most difficult,  subjective,  or complex
judgments,  often as a result of the need to make  estimates  about matters that
are  inherently  uncertain.  We have  discussed  with the  audit  committee  and
management our assessment of  management's  disclosures  regarding such policies
and  practices,  the reasons why these  policies and  practices  are  considered
critical,   and  how  current  and   anticipated   future  events  impact  those
determinations.

Quality of Accounting Principles

We have  discussed with the audit  committee and management our judgments  about
the quality, not just the acceptability,  of the Company's accounting principles
as applied in its financial reporting.  The discussions  generally included such
matters  as the  consistency  of the  Company's  accounting  policies  and their
application,  and  the  understandability  and  completeness  of  the  Company's
consolidated financial statements, which include related disclosures.

Management Judgments and Accounting Estimates

The preparation of the consolidated  financial statements requires management of
the  Company  to make a number of  estimates  and  assumptions  relating  to the
reported  amounts of assets and  liabilities  and the  disclosure  of contingent
assets and liabilities at the date of the consolidated  financial statements and
the  reported  amounts of  revenues  and  expenses  during the  period.  We have
discussed  with  you  certain  of  these  management  judgments  and  accounting
estimates  and  have  disclosed  control  deficiencies  that we  consider  to be
material  weaknesses in related areas in our letter to the Audit Committee dated
July 28, 2005.

Audit Adjustments

All-proposed audit adjustments were made by the Company.

Other Information in Documents Containing Audited Financial Statements

Our responsibility  for other information in documents  containing the Company's
consolidated  financial  statements  and our auditors'  report  thereon does not
extend beyond the financial information  identified in our auditors' report, and
we have no obligation to perform any procedures to corroborate other information
contained in these documents, for example,  Management's Discussion and Analysis
of Financial  Condition and Results of Operations.  We have,  however,  read the
other  information  included in the Company's  Form 10-K, and no matters came to
our attention that cause us to believe that such  information,  or its manner of
presentation,  is materially inconsistent with the information, or manner of its
presentation, appearing in the consolidated financial statements.

Disagreements with Management

There  were no  disagreements  with  management  on  financial  accounting,  and
reporting  matters that,  if not  satisfactorily  resolved,  would have caused a
modification  of our auditors'  report on the Company's  consolidated  financial
statements.

KPMG
Audit Committee
Collins Industries
July 28, 2005
Page 3


Difficulties Encountered in Performing the Audit

We encountered no significant  difficulties encountered in performing the audit,
except as disclosed to you regarding control deficiencies that we consider to be
material  weaknesses in our letter,  addressed to the Audit Committee of Collins
Industries,  dated July 28,  2005 and as related  to the  worker's  compensation
investigation  conducted by the audit  committee  and reported in the  Company's
footnote 2 of Form 10-K.

Material Written Communications

We have made material  written  communications,  between  management,  the audit
committee and ourselves,  including an engagement  letter addressed to the audit
committee,  material  control  weakness letter addressed to the audit committee,
audit committee representations signed by each member of the audit committee and
management  representation letter. Attached to this report please find a copy of
the management representation letter.

Independence

Our  professional  standards and other regulatory  requirements  specify that we
communicate  to you in  writing,  at least  annually,  all  independence-related
relationships  between our firm and the Company and provide confirmation that we
are independent accountants with respect to the Company. We are not aware of any
additional  independence-related  relationships between our firm and the Company
other than the professional services that have been provided to the Company.

The  fees  paid or  payable  to the  firm  relating  to the  audit  of the  2004
consolidated  financial statements and the fees for other professional  services
billed in 2004 are summarized in Item 14 Principal  Accounting Fees and Services
of Form 10-K.

Confirmation of Audit Independence

We hereby confirm that as of July 28, 2005, we are independent  accountants with
respect to the Company under all relevant professional and regulatory standards.

KPMG's System of Quality Control and Related Matters

The enclosed document entitled,  KPMG-Our System of Quality Controls,  including
the attached  addendum,  is being provided to communicate to you matters related
to KPMG's system of quality control.

                                  * * * * * * *

This report to the Audit  Committee is intended  solely for the  information and
use of the audit  committee and  management and is not intended to be and should
not be used by anyone  other than these  specified  parties.  This report is not
intended  for  general  use,  circulation  or  publication  and should not to be
published,  circulated,  reproduced  or used for any  purpose  without our prior
written permission in each specific instance.

Very truly yours,


/s/ KPMG LLP



cc: Cletus Glasener, Vice President of Finance and Chief Financial Officer

               KPMG LLP                            Telephone     816 802 5200
               Suite 1000                          Fax           816 802 5400
               1000 Walnut Street                  Internet      www.us.kpmg.com
               Kansas City, MO 64106-2162


July 28, 2005


The Audit Committee
Collins Industries, Inc.
Hutchinson, Kansas

Gentlemen:

We have audited the  consolidated  financial  statements of Collins  Industries,
Inc.  (Collins  or the  Company)  for the year ended  October  31, 2004 and have
issued  our  report  thereon  dated  July  28,  2005.  Our  report  includes  an
explanatory  paragraph disclosing that the 2003 and 2002 consolidated  financial
statements were restated.

In planning and performing our audit of the consolidated financial statements of
Collins,  we  considered  internal  control in order to  determine  our auditing
procedures  for the  purpose  of  expressing  our  opinion  on the  consolidated
financial  statements.  An audit does not include examining the effectiveness of
internal control and does not provide assurance on internal control. However, we
noted certain  matters  involving  internal  control and its  operation  that we
consider to be a material  weakness or significant  deficiency  under  standards
established by the Public Company Accounting  Oversight Board (United States). A
significant  deficiency  is a control  deficiency,  or  combination  of  control
deficiencies,   that  adversely  affects  the  Company's  ability  to  initiate,
authorize,  record,  process,  or report  external  financial  data  reliably in
accordance with generally accepted accounting principles such that there is more
than a remote  likelihood that a misstatement of the Company's annual or interim
financial  statements that is more than inconsequential will not be prevented or
detected.

A material weakness is a significant  deficiency,  or combination of significant
deficiencies,  that  results  in more than a remote  likelihood  that a material
misstatement of the annual or interim financial statements will not be prevented
or detected. In connection with our audit of the Company, we noted the following
control deficiencies that we consider to be material weaknesses:

Workers' Compensation Reserves

During the course of our audit,  we became aware that the Company did not record
reserves for workers'  compensation in accordance with U.S.  generally  accepted
accounting  principles and did not have  appropriate  policies and procedures to
ensure  the  estimates  provided  by  an  independent   insurance  adviser  were
appropriate. Specifically, the Company was "stair stepping" reserves for certain
claims  (i.e.  gradually  increasing  reserves for known  workers'  compensation
liabilities over a period of time, rather than recording them in the appropriate
period) and did not record the  estimated  ultimate  reserves for several  older
claims  that  involved  cases  where  employees   incurred   permanent   partial
disability.  Independent counsel retained by the audit committee determined that
certain  senior   management   representatives   dealt   aggressively  with  the
third-party administrator (TPA) and this caused reserves to be recorded at lower
levels than the TPA would otherwise have recommended.  Accounting personnel also
failed to maintain controls needed to ensure appropriate reserves were recorded.
As a result,  the  Company  determined  that it was  necessary  to  restate  its
historical consolidated financial statements to correct these errors.


           KPMG LLP, a U.S. limited liability partnership, is the U.S.
             member firm of KPMG International, a Swiss cooperative.

The Audit Committee
Collins Industries, Inc.
July 28, 2005
Page 2


Workers'  compensation reserves should be recorded at management's best estimate
of the ultimate liability of each claim.  Actuarial analysis should be performed
to substantiate the appropriateness of recorded reserves.  Accounting  personnel
should be more  diligent in  actively  overseeing  this area to ensure  recorded
reserves  are  made  in  accordance  with  U.S.  generally  accepted  accounting
principles.

Company Environment

The Company did not have effective policies and procedures  regarding management
override of  controls  and it did not have  effective  policies  and  procedures
implementing  its Code or Conduct.  As a result,  it did not  maintain a control
environment that promoted open and candid  communication within the organization
or with its outside  auditors.  We noted several  instances where ineffective or
inappropriate  communication  impeded the  accumulation of critical  information
needed to accurately record information for financial  reporting purposes and/or
cooperate  fully and  effectively  in the audit,  of the Company's  consolidated
financial statements. Examples of this are as follows.

•       During the investigation into the workers' compensation reserves, it was
        noted that senior management largely influenced the reserve  recommended
        by the TPA.  Specifically,  the chief operating officer directed the TPA
        responsible  for   recommending   workers'   compensation   reserves  to
        "stair-step" the reserve recommendation and was aware of the older cases
        that  did  not  have  reserves  recorded  for  the  estimated   ultimate
        liability.  There  also  was  correspondence  from the  chief  financial
        officer  that  indicated he was aware of the  "stair-stepping"  and that
        "KPMG may have a problem with this."

•       Several invoices from a contractor totaling approximately $45,000 at one
        of the Company's  subsidiaries were not recorded during fiscal 2004 when
        the work was performed.  Instead,  the plant manager or accounts payable
        clerk attempted to process these invoices over a number of months during
        the 2005 fiscal year.

•       Correspondence  from  the  Ohio  Environmental  Protection  Agency  (the
        Agency) indicated that some of the Company's documentation to the Agency
        had apparently been falsified.

•       The plant manager at Mid Bus apparently manipulated amounts reported for
        work-in-progress  units as being more complete than they actually  were.
        Correspondence would suggest the plant manager, who was terminated, felt
        pressured to report  inappropriate  information to meet  expectations of
        senior management.

Senior  management  needs to  create  an  atmosphere  where  employees  can feel
comfortable and report information  candidly up and down the organization and to
KPMG without fear of reprisal.  We believe the four  documented  items noted are
indicative of a material  control  weakness in overall  company level  controls.
This  is an  issue  that  deserves  immediate  board  of  directors  and  senior
management  attention.  Without the board of directors  and senior  management's
attention  and  focus,  this   "tone-at-the-top"   issue  cannot  be  adequately
addressed.

Significant deficiencies, which have been discussed with the appropriate members
of management, are summarized as follows:

The Audit Committee
Collins Industries, Inc.
July 28, 2005
Page 3


Hazardous Waste Management and Reporting at Mid Bus

Correspondence  from the Agency  severely  criticized  Mid Bus.  The  regulators
asserted  Mid Bus fails to  understand  or accept that  violations  of hazardous
waste rules and statutes have great  potential  for harm.  The  regulators  also
noted  Mid Bus had  failed  in its  continuing  obligation  to  properly  manage
hazardous  waste,  and its apparent  falsification of records makes a mockery of
the self reporting program used in Ohio.

This correspondence  indicates,  at a minimum,  that there are potential serious
deficiencies in procedures used by Mid Bus to manage and report hazardous waste.
We recommend  procedures used to manage and report hazardous waste at Mid Bus be
reevaluated  and  corrective  action  taken to address the  concerns of the Ohio
regulator.

Inventory

The Company does not have a perpetual  inventory system and performs a perpetual
inventory and updates standard  inventory costs only once per year. As a result,
the Company experienced an inventory adjustment of approximately $850,000 during
the fourth quarter of fiscal 2004.

                                  * * * * * * *

These conditions were considered in determining the nature,  timing,  and extent
of the  audit  tests  applied  in our  audit  of the  fiscal  2004  consolidated
financial  statements,  and in the restatement of the 2003 and 2002 consolidated
financial  statements,  and this  report  does not  affect  our  report on these
consolidated  financial  statements  dated July 28, 2005. We have not considered
internal control since the date of our report.

This  report  is  intended  solely  for the  information  and  use of the  audit
committee, management, and others within the organization and is not intended to
be, and should not be, used by anyone other than these specified parties.

Very truly yours,


/s/ KPMG LLP