Interpretation ID: nht91-3.29

DATE: April 26, 1991

FROM: John Marcum -- Electric Vehicles, S.A.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9-11-91 from Paul Jackson Rice to John Marcum (A38; Part 591; VSA S108(j))

TEXT:

Thank you for your letter of 22 April, 1991 concerning EVSA's request for a temporary exemption from the Federal motor vehicle safety standards for its prototype electric minibus. I understand that the exemption is not possible since it was requested after the vehicle was manufactured.

As you point out, however, this imported minibus is evidently exempted from compliance for up to 5 years since it is being used for "research, investigations studies or demonstrations or training". The "research, investigations and studies" references seems clear enough, but I would appreciate clarification as to whether "demonstration and training" can include the carrying of passengers for demonstration and evaluation services. If so, are there any special conditions that must be observed. For example, could the passengers pay for the rides or should the rides be free? Is there a limit as to the length of time during which the passenger demonstration phase is scheduled?

We are reviewing the regulations you sent us and will provide any further information that may be needed.