Interpretation ID: nht90-3.55

TYPE: Interpretation-NHTSA

DATE: August 14, 1990

FROM: Gerald F. Vinci -- Sun Refining and Marketing Company

TO: Paul Jackson Rice -- Office of the Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9-17-90 from P.J. Rice to G.F. Vinci (A36; FMVSS 301; VSA 108(b)(1)); Also attached to letter dated 8-17-79 from F. Berndt (Signature by S.P. Wood) to M. Champagne

TEXT:

Our research and development department at Sun Refining and Marketing Company is interested in converting the fuel system of a new vehicle from gasoline to propane. Sun does not intend to act as a manufacturer. The only portion of the vehicle which wil l be substantially altered is the fuel system. The vehicle is intended to be driven under normal traffic conditions and would maintain a lower emission level than that required under the Clean Air Act.

I spoke recently with Dee Fujita and Taylor Vinson of the Chief Counsel's Office. After factually reviewing the project, both concluded that such a vehicle would not violate the National Traffic and Motor Vehicle Safety Act and its regulations. Ms. Fuj ita and Mr. Vinson did however caution that there may be requirements under state law.

We recognize the importance of highway safety and intend to fully comply with all applicable federal laws. To assist us, I respectfully request an opinion letter addressing compliance of such a vehicle with the Act and its regulations. If you need any additional information, please contact me at (215)246-8251.