A 2013 INTERNATIONAL CE 3000 SPECIAL NEEDS LIFT BUS WAS ON A MORNING ROUTE WHICH HAS EXISTED FOR MANY YEARS. IT ENTERED AN APARTMENT COMPLEX DRIVEWAY WITHOUT ANY ISSUES. UPON EXITING THE APARTMENT COMPLEX THE BRAKE AIR TANK HIT AND RUBBED THE GROUND BREAKING OFF THREE VALVES. THE BUS ROLLED APPROXIMATELY 25 MORE FEET AND THEN THE BRAKES LOCKED. IT HAPPENED A SECOND TIME THIS YEAR. NONE OF OUR 230 OTHER BUSES IN OUR FLEET EVEN COME CLOSE TO IMPACTING THE GROUND AT THIS APARTMENT COMPLEX. THIS NEWER LOW AIR TANK CONFIGURATION IS AN EXTREME SAFETY HAZARD ESPECIALLY IF IT WERE CROSSING RAILROAD TRACKS WITH SPECIAL NEEDS STUDENTS ON BOARD. INTERNATIONAL CHANGED THE DESIGN AND CONFIGURATION OF THE AIR TANKS IN 2013 FROM PREVIOUS YEAR MODELS. PREVIOUS YEAR MODELS HAD THE TANKS WELL ABOVE THE CHASSIS FRAME AND WERE NEVER AN ISSUE. *TR