Interpretation ID: nht91-5.20

DATE: August 9, 1991

FROM: David L. Kulp -- Manager, Fuel Economy Planning & Compliance, Environmental and Safety Engineering Staff, Ford Motor Company

TO: Orron E. Kee -- NHTSA

TITLE: Reference: Deletion of Off-Highway Data from the Pre-Model and Mid-Model Reports

ATTACHMT: Attached to letter dated 10-23-91 from Paul Jackson Rice to David L. Kulp (A38; Part 523; Part 537)

TEXT:

Ford requests your concurrence to discontinue the reporting of off-highway data as listed in S537.7(c)(5) for light-duty trucks that otherwise comply to the light-duty truck definition in S523.5(a). Per a telephone conversation between you and Ms. Peg Gutmann of my staff on July 19, 1991, the off-highway data is only required for automobiles that a manufacturer wishes to classify as a light-duty truck per the provisions of S523.5(b).

Please contact Ms. Gutmann at (313) 337-5367 if you have any questions or concerns.