ID: 10755

Mr. David T. Holland
President
Europa International, Inc.
1570A Pacheco Street
Santa Fe, NM 87505

Dear Mr. Holland:

This responds to your letter of February 24, 1995, regarding the passive restraint phase-in requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection. You asked whether an importer which "imports Canadian specification MPV's (multipurpose passenger vehicles), such as the Chrysler Minivan, that meets (sic) the MPV passive restraint requirements of FMVSS 208 ... can count these vehicles toward the required percentage."

Section S4.2.5.6.1(a) states, "(a) vehicle that is imported shall be attributed to the importer." Thus, to determine compliance with the passive restraint phase-in requirements, Europa International should (1) count all trucks, buses, and mpv's with a gross vehicle weight rating of 8,500 pounds or less and an unloaded vehicle weight of 5,500 pounds or less, (2) count all such vehicles which meet the passive restraint requirements of FMVSS 208, and (3) determine if that class of vehicles is a sufficient percentage of the first class of vehicles to satisfy the phase-in requirements. However, as Mary Versailles of my staff cautioned you on the phone, some manufacturers are installing European (face) air bags but are not certifying that vehicles with such air bags meet the passive restraint requirements of FMVSS 208. Therefore, you should verify that any vehicle with an air bag is in fact certified to FMVSS 208's passive restraint requirements.

I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Philip R. Recht Chief Counsel ref:208 d:4/3/95

ID: nht88-4.17

TYPE: INTERPRETATION-NHTSA

DATE: 11/26/88

FROM: M. M. YOON -- DIRECTOR, IN-ONE DEVELOPMENT CORP. SEOUL, KOREA

TO: STEVE KRATZTE -- OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/31/89 FROM ERIKA Z. JONES -- NHTSA TO M. J. YOON, REDBOOK A33 (2), PART 571.3

TEXT: DEAR, MR. KRATZTE

WE, IN-ONE DEVELOPMENT CORP., ARE DOING AS RESEARCH AND DEVELOPMENT CENTER OF SSANGYONG MOTOR COMPANY, PROCEEDING TWO PROJECTS WHICH ONE OFF-ROAD VEHICLE AND ONE PASSENGER CAR AND PLANNING TO LAUNCH THE CARS IN U.S.A.

THEREFORE, WE WOULD LIKE TO KNOW THE VEHICLE CLASSIFICATIONS (PASSENGER CAR OR MULTIPURPOSE PASSENGER CAR) OF OFF-ROAD VEHICLES PLANNED TO PRODUCT IN THE END OF 1991.

FOR YOUR REFERENCE, GENERAL SPECIFICATIONS OF THE VEHICLE ARE AS FOLLOWS.

OVERALL LENGTH: 4200 approx. 4250 mm, DRIVE SYSTEM: 4 WHEEL DRIVE (PART TIME)

OVERALL WIDTH: 1716 mm, FRAME: LADDER TYPE FRAME

HEIGHT (ON GROUND): 1670 approx. 1700 mm

WINDSCREEN SLOPE ANGLE: 55 degrees

APPROACH ANGLE: 40 degrees

DEPARTUER ANGLE: 30 degrees

GROUND CLEARANCE (IN LADEN CONDITION): MINIMUM 200 mm

(THE SHAPE OF THE VEHICLE LOOKS LIKE PASSENGER CAR; AERODYNAMIC SHAPE)

AND, WE ALSO WANT TO KNOW THE CRITERIA FOR VEHICLE TYPE CLASSIFICATIONS. YOU ARE KINDLY REQUESTED TO SENT THE INFORMATIONS, IF AVAILABLE. WE ARE LOOKING FORWARD TO YOUR PROMPT RESPONSE. NOTE). OUR ADDRESS & FAX. NO ARE AS FOLLOWS.

ADDRESS: 2nd FLOOR, GUKDONG BUILDING, 3-GA CHUNGMOO-RO, JUNG-GU, SEOUL, KOREA.

FAX. NO: 02-277-5321

SINCERELY YOURS

ID: nht90-2.91

TYPE: Interpretation-NHTSA

DATE: June 20, 1990

FROM: Dennis T. Johnston -- Senior Executive Engineer, Product Engineering and Regulatory Affairs, Sterling Motor Cars

TO: General Jerry R. Curry -- Administrator, NHTSA

TITLE: Re Sterling Superlocking System

ATTACHMT: Attached to letter dated 10-5-90 from B. Felrice to D.T. Johnston (A36; Part 543)

TEXT:

Rover Cars of North America (formerly Austin Rover Cars of North America, d.b.a. Sterling Motor Cars), importer of the British Sterling passenger car, manufactured by the Rover Group Ltd., U.K. sent you a letter dated March 14, 1990 outlining a proposed modification to our antitheft system in the 1991 Model Year. Due to marketing considerations, this enhanced system, referred to as 'superlocking' will not be available for the 1991 Model Year. Therefore Sterling would like to withdraw that submission. If we elect to offer this system at some point in the future we will resubmit a request for de minimus change to our currently approved theft prevention system.

We would like to introduce a minor revision to our currently approved system for the 1991 Model Year, however. Our present system, once armed, will activate if the trunk is opened, even using the key, unless the system is disarmed. Our proposed modific ation would allow the system to be disarmed when the trunk is opened by the key and rearmed when the, trunk lid is closed. Forcing open of the trunk without using the key would still activate the alarm.

If you have any questions regarding this request please feel free to contact me on (213) 437-6282 at your earliest convenience.

ID: 2407y

Dipl.-Ing. H. Westermann
Hella KG Hueck & Co.
Postfach 28 40
4780 Lippstadt
West Germany

Dear Herr Westermann:

This is in reply to your letter of February 21, l990, to Taylor Vinson of this Office, requesting an interpretation of Motor Vehicle Safety Standard No. 108 with respect to whether two designs for center highmounted stop lamps (CHMSL) you enclosed are permissible. You wish to know whether the ECE definition of "lamp unity" can be applied, and whether the designs form a CHMSL unity in the sense of Standard No. 108.

The question, as we see it, is not whether the ECE definition can be applied, but whether the two designs you submitted would meet the clearly expressed requirements of Standard No. 108. The standard requires that there be a single lamp, that it have an effective projected luminous area of not less than 4 1/2 square inches, that its signal be visible through a horizontal angle from 45 degrees to the left to 45 degrees to the right of the longitudinal axis of the vehicle, and that it provide specified minimum photometric values at 13 specific test points.

The design represented in Enclosure l appears to pass through the center of the lamp, at the H-V test point, thus affecting compliance of the lamp. Measurement at test points can only be determined by photometric testing. The design represented in Enclosure 2 would not comply with the standard. It is, in effect, two lamps mounted symmetrically about the vertical centerline. Standard No. l08 requires a single lamp, to be mounted on the vertical centerline.

Sincerely,

Stephen P. Wood Acting Chief Counsel

ref:l08 d:4/25/90

ID: 2640o

Mr. Toshio Maeda
Executive Vice President
& Chief Operating Officer
Nissan Research & Development, Inc.
P.O. Box 8650
Ann Arbor, Michigan 48104

Dear Mr. Maeda:

This is in reply to your letter of June 30, 1987, asking for an interpretation of paragraph S4.1.1.36(b)(3) of Motor Vehicle Safety Standard No. l08.

That paragraph specifies in pertinent part that a replaceable bulb headlamp shall be designed to conform to Section 6.1-Aiming Adjustment Test, of SAE Standard J580 AUG79 Sealed Beam Headlamp Assembly. Section 6.1.1 states that "when the headlamp assembly is tested in the laboratory, a minimum aiming adjustment of +/-4 deg. shall be provided in both the vertical and horizontal planes." You have asked whether the aiming adjustment is to be achieved by the headlamp assembly, or by both the headlamp assembly "and by the headlamp when it is mounted on the vehicle."

SAE J580 applies to the design of headlamp assemblies, including the functional parts other than the headlamps, such as aiming and mounting mechanisms and hardware. The assembly may include one or more headlamps. Although the headlamp assembly is tested in the laboratory, its design must be identical to the headlamp assembly used on the vehicle. Thus, if the aiming adjustment requirement is met by the headlamp assembly in the laboratory, it should also be met when the assembly is installed on the vehicle. An individual headlamp installed on the vehicle need not meet the aiming adjustment test unless that headlamp is part of a headlamp assembly comprising only one headlamp.

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel ref:l08 d:1/14/88

ID: nht87-1.1

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/87 EST

FROM: S.L. LEPOSKY -- EQUIPMENT SUPPLY CO

TO: ALL DISTRIBUTORS AND SALESMEN.

TITLE: NON USE OF DUCK BILLED STEEL TIRE HAMMERS

ATTACHMT: ATTACHED TO LETTER DATED 02/11/88 FROM ERIKA Z JONES TO BETH WHITMAN; REDBOOK A31, STANDARD 110, 120; SA 19 AR STEELHAMMERS 2J; SA 29 STEELHAMMERS 2J; LETTER DATED 01/21/87 FROM S. L. LEPOSKY TO DISTRIBUTORS; LETTER DATED 07/09/87 FROM LEO CARE Y TO BETH WHITMAN

TEXT: We have just returned from the annual National Wheel & Rim Meeting in Phoenix, Arizona. The tone of the meeting from Wheel & Rim Manufacturers was one of concern and rightly so. They have all reprinted and issued their new Rim & Tire Service Manuals ou t-lining and telling tire dealers, fleets, mining and construction users that they MUST NOT USE steel hammers to disassemble or assemble truck rim components. The practice still goes on and probably will until more people are injured and more lawsuits f iled.

For your convenience we have enclosed two pieces of instruction material produced by Rubber Manufacturers Association (RMA) and National Highway, Traffic Safety & Health Administration (NHTSHA). Have your salesmen carry this with them and discuss it wit h your customers.

The logical alternative to the steel duck bill hammer is the "COMBI" Truck & Farm Tire Bead Breaker. If your people will talk about the regulations, your customers will soon start to buy the proper equipment to replace the hammer.

One of the best places to start is with local City, County, State and Federal service operations. They are very cognizant of the OSHA regulations.

ID: nht80-4.12

DATE: 10/20/80

FROM: Frank Berndt; NHTSA

TO: OVSC

TITLE: OVSC Investigatory Activities Concerning Possible Violations of UTQGS Treadwear Grading Requirements

TEXT: This responds to your request for direction concerning when the Office of Vehicle Safety Compliance, Enforcement, must open a formal standards enforcement investigation (known as a "CIR" [certification information request] of a possible noncompliance with the treadwear grading requirements of the Uniform Tire Quality Grading Standards (UTQGS), 49 CER 575.104.

UTQGS is a consumer information regulation. While the regulation does require tire manufacturers to provide grading information in the important safety areas of traction and temperature resistance, the treadwear grades, on the other hand, are primarily economic rather than safety information. Moreover, as a consumer information regulation, UTQGS requires no minimum level of safety performance, but, rather, requires relative ranking information. Under these circumstances, we do not believe that it is imperative that a CIR be opened immediately whenever there is a testing result indicating that a small number of tires may be at variance with their manufacturer's rating. OVSC may conduct further testing and/or analysis, including inquiry to the manufacturer, prior to opening a CIR. (Any records of these activities will be treated according to the particular applicability of the Freedom of Information Act.) Such a practice is akin to the Office of Defects Investigation conducting a preliminary inquiry of engineering analysis, which may or may not lead to the opening of a formal defect case investigation.

So that the public and the industry may understand this direction, we are placing a copy of this memorandum in the Interpretations File in the Technical Reference Library, and sending a copy to the Rubber Manufacturers Association.

ID: 77-4.26

TYPE: INTERPRETATION-NHTSA

DATE: 11/03/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr; NHTSA

TO: American Trailers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 20, 1977, letter asking whether your certification labels comply with Part 567, Certification, and Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.

As stated to you in an earlier letter, the National Highway Traffic Safety Administration does not issue approvals of compliance with Federal safety standards or regulations. The agency will, however, give you an informal opinion as to whether your labels appear to comply with the requirements. The agency has determined that the two labels that you submitted do not follow the format established in the regulations and, therefore, do not comply with the requirements. If "R" denotes radial ply and "F" denotes load range, the tire designation should be 10.00 R 20 (F).

SINCERELY,

American Trailers, Inc.

July 20, 1977

Roger Tilton Office of the Chief Counsel National Highway Traffic Safety Admin.

SUBJECT: NOA-30 (RST)

This letter is to confirm our telephone conversation of July 19, concerning Mr. Levin's letter of July 13, 1977.

We are enclosing two new samples certification labels which have been modified from the original as submitted May 25, 1977. It is our understanding that the changes in the wording for the tire and rim size, and the deletion of the wording "maximum with minimum size tire-rims shown below" will give apparent compliance with the requirements of Part 567 and Standard No. 120.

Jerry McNeil Director of Engineering

ENCLS.

ID: 77-3.16

TYPE: INTERPRETATION-NHTSA

DATE: 07/01/77

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Hon. Clarence D. Long - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of May 9, 1977, to the Federal Trade Commission, on behalf of Mr. Edward L. Armstrong, Sr., Baltimore, Maryland, expressing his concern that new passenger car manufacturers will discontinue supplying spare tires, has been referred to this office of the National Highway Traffic Safety Administration, Department of Transportation, for additional consideration and reply.

We believe that Mr. Armstrong's concern deals with the recently approved "temporary use" spare tire that will be manufactured and used with some of the new 1978 model automobiles. The use of a temporary use spare tire is not a new concept. These tires have been used with compact sport cars, such as Firebird and Camaro, since 1967. The further development of these spare tires has been fostered by the desire of the U.S. automobile manufacturers to produce small, lightweight cars in furtherance of the national energy conservation program. I am sure that you have noticed the new 1977 models by some domestic automobile manufacturers are, in fact, smaller. Of course, the development of these smaller, lightweight, energy-efficient automobiles has resulted in a substantial reduction in usable car trunk space, and therefore, providing a second reason to develop a spare tire which takes less storage space than a conventional tire.

Since this spare tire is designed for use on the nation's highways, it must conform to the minimum performance requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 109, New Pneumatic Tires - Passenger Cars, for strength, endurance and high speed performance. For your information, we have enclosed a copy of this standard.

ID: nht93-3.32

DATE: May 4, 1993

FROM: St. F. Steiner -- Consultant, AET Network

TO: John Womack -- Chief Council, U.S. Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5-17-93 from John Womack (Signature by Stephen P. Wood) to St. F. Steiner (A41; Part 591)

TEXT: As an environmentally, concerned company, our goal is to become proactive before the new California 2010 Emissions State Law is to be effective and the President of the United States signs the new Environmental Protection Laws. We think it's time to aggressively contribute in the development of human responsibility and thus, build up an agreeable base for our children and future.

Because of this, our company is into environmental protection by way of contributing toward the reduction of gasoline pollution attributed to the transportation industry. In our efforts, our goal is to import electric automobiles from Europe for research and exploration. In order to do this, we need your assistance on the following U.S. laws and D.O.T. requirements for 3 and 4 wheelers with 1 to 5 passengers.

o Are there any safety standards and regulations for the above mentioned automobiles?

o Is there a minimum speed standard regulation for the above mentioned automobiles?

o Are there weight limitations for the above mentioned automobiles?

o What conversions would be required in order to meet U.S. specifications and standards? o Could these automobiles be permitted on highways?

Thank you for taking the time to review our needs. Your immediate response and assistance would be greatly appreciated in supporting our effort towards improving our environment. If you should inquire additional information about our electric automobiles please feel free to contact us.