ID: nht76-3.24

DATE: 02/27/76

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Northern Coach Inc.

TITLE: FMVSR INTERPRETATION

TEXT: I am writing to confirm your telephone conversation of February 25, 1976, with Mark Schwimmer of this office, concerning the certification of school buses.

As Mr. Schwimmer explained, this agency does not certify or otherwise issue advance approvals of motor vehicles or motor vehicle equipment. Certification, under the applicable law and regulations, must be done by the vehicle manufacturer, including a final-stage manufacturer such as you. Your certification obligation, as a final stage manufacturer of school buses, is met if you fulfill the requirements of 49 CFR Part 567, with which I understand you are already familiar.

An information sheet entitled "Where to Obtain Federal Motor Vehicle Safety Standards and Regulations" is enclosed for your convenience. Please write if we can be of any further assistance.

ID: nht76-3.25

DATE: 08/19/76

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Modular Ambulance Corp.

TITLE: FMVSR INTERPETATION

TEXT: We have received your letter of July 26, 1976, petitioning for a temporary exemption from Motor Vehicle Safety Standard No. 301-75. When you forward the financial statements promised we shall prepare a notice for the Federal Register.

I would like to comment on two aspects of your petition. The first is that in our opinion, each manufacturer supplying you with a chassis is an "incomplete vehicle" manufacturer as defined by 49 CFR Part 568, and should be able to provide you with sufficient information, in the incomplete vehicle document accompanying each chassis, to enable you to insure that your ambulances upon completion conform with Standard No. 301-75. I enclose a copy of a recent letter that we sent General Motors expressing our views on this subject. Since your problem is basically similar, as part of your good faith efforts to meet Standard No. 301-75 you should attempt to obtain compliance information from your chassis manufacturers as soon as you can. We would like to be informed if you are unable to obtain this information.

My second comment is that your petition presents the "worst case" approach, based upon the presumed necessity to crash test each of the 11 models you manufacture. As a matter of clarification, there is no legal requirement that a manufacturer conduct a barrier test before he certifies compliance with Standard No. 301-75. He must, however, have a reasonable basis for certification that the vehicle, if barrier tested, would meet Standard No. 301-75. Many manufacturers prefer the assurance that is provided by testing according to a standard's procedure. However, engineering calculations, computer simulations, etc., can often provide a reasonable basis for certification. You may wish to reevaluate your petition's cost estimates in light of this.

ID: nht76-3.26

DATE: 03/15/76

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: NAFDEM

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 26, 1976, concerning procedures for the certification of trucks on which your member companies mount tanks for the transportation of food and dairy products. The letter requested our review of six procedures agreed to by your members for compliance with the Federal certification requirements. The procedures are restated below along with our comments.

1. "Member companies agree to assume the responsibility for notification and instruction of customers to select a truck chassis with a loaded and axle capacity rating equal to or exceeding the total weight of the completed truck chassis, i.e., chassis, tank, and payload, in order to comply with Federal safety standards."

We encourage this practice. Please note, however, that the customer himself has no duty under the National Traffic and Motor Vehicle Safety Act of 1966, as amended ("the Act"), the Federal motor vehicle safety standards, or applicable regulations, to select a chassis with sufficient load ratings. The duty is your member companies', when presented with chassis of insufficient load ratings, to refrain from mounting tanks.

2. "Member companies agree to assume the responsibility for notification and instruction of a customer when his new vehicle is received to obtain an incomplete vehicle certification supplied by the truck manufacturer, and to retain this certification in the truck cab until his tank is mounted as a complete unit."

Assuming that by "incomplete vehicle certification supplied by the truck manufacturer" you mean the document referred to in @ 568.4 of 49 CFR Part 568, Vehicles Manufactured in Two or More Stages, we encourage this practice as well. Please note once again, however, that the customer has no duty under applicable law to obtain or retain the document. Provision of the document is the duty of the chassis manufacturer. While your members are free to require of their customers the obtaining and retention of the document, this would be a solely contractual requirement.

3. "In the event that the customer has the chassis altered by an intermediate party such as lengthening the frame, adding an axle, or changing tire size and/or specifications, member companies agree to advise the customer of his responsibility for obtaining from the intermediate shop a certificate stating the new gross vehicle weight rating and new gross axle weight rating, and that the vehicle complies with all Federal motor vehicle safety standards."

This does not correctly state the applicable law, for the reasons discussed in #2 above. Pursuant to @ 568.5, it is the duty of the intermediate manufacturer to pass on the incomplete vehicle document. The customer's duty is a matter of private contract. Further, the incomplete vehicle document need not certify that the chassis complies with all Federal motor vehicle safety standards. It must simply provide the statements and information set out in @ 568.4(a), with such addendum as may be necessary.

4. "The member company, as a transportation tank manufacturer, at the time of mounting the customer's tank on the new truck chassis at his plant, will be responsible to certify through the preparation of a completed vehicle certification that the unit complies with requirements set forth by the National Highway Traffic Safety Administration."

That is correct.

5. "When a new truck chassis is received at a member company's plant for mounting with no or improper "incomplete vehicle certification" documents, the vehicle will be certified for "no load" carrying capacity."

This practice is improper. A vehicle may not be certified for "no load" carrying capacity. @ 567.5 of 49 CFR Part 567, Certification, requires that Gross Vehicle Weight Rating (GVWR) and Gross Axle Weight Ratings (GAWR's) be stated, @ 567.5(a)(5) explicity provides that the GVWR:

shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity. . .

Further, where your member company mounts a tank that is designed to carry a particular commodity, the rated cargo load on which he bases the ratings should not be less than what he can reasonably expect the user to consider a "full load" of that commodity. The incomplete vehicle document is designed to protect the final stage manufacturer in his certification of the completed vehicle.

6. "When the gross vehicle weight ratings or gross vehicle axle ratings are less than the required rating for the capacity of the tank, the member company will state the limited carrying capacity to meet Federal standards on the certification document."

For the reasons discussed in #5 above, this practice is not necessarily proper. In particular, if it is reasonable to expect that the user will load the vehicle to its full volumetric capacity despite your member company's specification on the certification plate of a "limited carrying capacity", then the vehicle would probably be considered to contain a safety-related defect, subject to the notification and remedy provisions of the Act.

If you have any further questions, please feel free to write.

ID: nht76-3.27

DATE: 05/12/76

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood; NHTSA

TO: Willamette Wheel Inc.

TITLE: FMVSR INTERPRETATION

TEXT: I am writing in response to your April 21, 1976, telephone conversation with Mark Schwimmer of this office, concerning the modification work that you perform on previously certified Datsun pickup trucks, which consists of converting them from two-wheel- to four-wheel-drive vehicles.

As indicated in the October 30, 1975, letter from Richard B. Dyson to you, you are a vehicle alterer who is subject to the requirements of 49 CFR 567.7. That section requires that you affix a label to the vehicle stating that, as altered, the vehicle conforms to applicable Federal motor vehicle safety standards.

The Federal government does not certify or otherwise issue advance approval of motor vehicles. As Mr. Schwimmer explained, the statement on the label constitutes your certification of conformity. If you fail to provide this certification, or if in the exercise of due care you have reason to know that it is false or misleading, you are subject to civil penalties under the National Traffic and Motor Vehicle Safety Act of 1966, as amended.

All altered vehicles must comply fully with all applicable safety standards. Therefore, as Mr. Schwimmer further explained, you would not be relieved of the requirements of @ 567.7 simply by virtue of the fact that, as altered, the vehicle complied fully with the standards. You would be relieved of the requirements only if both of the following conditions were met:

(i) the alteration is performed solely by the addition, substitution, or removal of readily attachable components such as tire and rim assemblies, or by minor finishing operations such as painting; and

(ii) the stated weight ratings of the vehicle are still valid.

Because the conversion of the vehicles in question does not meet the first condition, you are subject to the requirements of @ 567.7. Please note further that, if your modifications affect the validity of the weight ratings assigned to the vehicles by Datsun, your label must show valid, modified ratings.

An information sheet entitled "Where to Obtain Federal Motor Vehicle Safety Standards and Regulations" is enclosed for your convenience.

ID: nht76-3.28

DATE: 11/10/76

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: United Recreational Products Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your July 16, 1976, request for information on the requirements for a manufacturer of a light utility trailer which is designed to carry snowmobiles. I regret that we have not responded sooner.

The information you request appears in Title 49 of the Code of Federal Regulations, and I enclose an information sheet which explains how this material may be acquired.

Part 566, Manufacturer Identification (49 CFR Part 566), specifies identification information which must be submitted to the NHTSA by manufacturers of vehicles and equipment regulated by our standards.

Part 567, Certification (49 CFR Part 567), specifies the content and location of the certification label or tag which must be attached to motor vehicles regulated by our standards.

At this time the only Federal safety standards applicable to all trailers are Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, and Standard No. 120, Tire and Rim Selection for Vehicles Other Than Passenger Cars. The enclosed information sheet also explains how to acquire those regulations.

Standard No. 121, Air brake systems, became effective on January 1, 1975, in the case of trailers which the manufacturer has decided to equip with air brakes. Thus trailers which you manufacture on or after January 1, 1975, which utilize air brakes must meet the air brake standard.

After you have reviewed the regulations I have referred to, please contact me if you have any further questions.

ID: nht76-3.29

DATE: 03/12/76

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Maurice J. Sopp & Son

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 27, 1976, concerning the sale of a 1975 Chevrolet Step Van that has been modified by the addition of a "boiler" assembly.

@@ 567.4(g)(3) and 567.5(a)(5) of 49 CFR Part 567, Certification, provide that the Gross Vehicle Weight Rating (GVWR) appearing on the certification label

shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity . . .

Further, @ 567.7 provides that a person who, before the first purchase in good faith for purposes other than resale, alters a previously certified vehicle in such a manner that its stated weight ratings are no longer valid shall affix to the vehicle an additional label that certifies the modified weight ratings and the vehicle's continued compliance with applicable Federal motor vehicle safety standards.

Your letter indicates that the unloaded weight of the van, as altered by Steamaster Boiler Co., exceeds the original 10,000 pound GVWR. From this information, it appears that there has been a violation of the Certification regulation. While we would have to investigate your role as the dealer in this transaction to determine your precise liability, we advise you not to sell the vehicle in its present condition.

ID: nht76-3.3

DATE: 05/05/76

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your April 14, 1976, letter concerning the meaning of the effective dates of Federal motor vehicle safety standards.

You are correct in your understanding that a vehicle's date of sale is irrelevant to a determination of which standards are applicable to it. 49 CFR @ 571.7(a), Applicability, specifies in relevant part:

. . . each standard . . . applies according to its terms to all motor vehicles or items of motor vehicle equipment the manufacturer of which is completed on or after the effective date of the standard.

For vehicles that you complete by mounting a body on a chassis, you are permitted by 49 CFR @ 567.5(a) (7) to treat as the time that manufacture is "completed" for the purposes of @ 571.7(a) any date no earlier than the manufacturing date of the incomplete vehicle and no later than the date of completion of final-stage manufacture, regardless of when the body or chassis was sold. Please note that you must be consistent in your choice of completion date, e.g., you may not choose one date to determine applicability of certain standards while choosing another date for other standards.

ID: nht76-3.30

DATE: 06/04/76

FROM: AUTHOR UNAVAILABLE; James B. Gregory; NHTSA

TO: Honorable John M. Murphy; House of Representatives

COPYEE: CONGRESSMAN VAN DEELIN

TITLE: FMVSR INTERPRETATION

TEXT: I am writing in response to former Chairman Lionel Van Deerlin's April 21, 1976, letter concerning Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity, as applied to motor homes. His letter is particularly concerned with the request of the Recreational Vehicle Industry Association (RVIA) for a delay in the standard's effective date of September 1, 1976, for the first phase of the requirements that apply to motor homes.

This effective date requires clarification in the case of multi-stage vehicles. RVIA members typically manufacture motor homes by installing bodies on chassis that have been supplied to them by other manufacturers. In such situations, the meaning of the September 1, 1976, effective date is not that all motor homes completed after that date must comply with the standard. Section 567.5(a)(7) of 49 CFR Part 567, Certification, permits the final stage manufacturer of a multi-stage vehicle to consider as the vehicle's date of manufacture any date that is neither earlier than the completion date of the chassis nor later than the completion date of the entire vehicle. The practical result of this provision is that the standard requires compliance only of those motor homes whose chassis are completed on or after September 1, 1976.

Because the ability of a motor home to comply with Standard No. 301-75 is substantially affected by both the design of the chassis and the manner in which the vehicle is completed, it is not meaningful to apply the standard directly to incomplete vehicles. All that the National Highway Traffic Safety Administration (NHTSA) requires of incomplete vehicles is the following: those that are manufactured after September 1, 1976, must be capable of being completed into complying motor homes and must be accompanied by the incomplete vehicle document described in 49 CFR Part 568, Vehicles Manufactured in Two or More Stages. That document will include, with respect to Standard No. 301-75, either (i) a statement that the motor home as completed will comply with the standard provided no alterations are made in identified components of the incomplete vehicle, or (ii) a statement of specific conditions of final manufacture under which the completed motor home will comply with the standard. While Part 568 generally offers the incomplete vehicle manufacturer a third option -- to make no representation whatever of the compliance status of his product -- that option is unavailable in this context because his work substantially affects compliance.

The RVIA has argued that a delay in the standard's effective date for completed motor homes is necessary for its members to gain experience with chassis that have been designed for completion into complying motor homes. The NHTSA recognizes the need for such experience or its equivalent through the provision of technical information by the incomplete vehicle manufacturer. However, the agency expects motor home manufacturers to obtain this experience or information, through cooperation with the chassis manufacturers, in advance of the September 1, 1976, effective date. While such advance manufacturing or provision of information on the part of chassis manufacturers is not required by any regulations of this agency, it is required by the commercial realities of their relationships with the motor home manufacturers. A simple delay in the standard's effective date would merely delay the date by which incomplete vehicle manufacturers would be required by the NHTSA to supply chassis that have been designed for completion into complying motor homes. Such a delay would thus not provide the relief that the RVIA has requested.

The RVIA has, in effect, requested the agency to establish an "experience interval" by retaining September 1, 1976, as the time by which chassis must be designed for ultimate compliance and setting a new and later "secondary" effective date for the activities of the RVIA members. With this approach, a completed motor home would be required to comply with Standard No. 301-75 only if it were based on a chassis manufactured after the secondary effective date. While the establishment of such an "experience interval" might at first appear to be a simple solution to an acknowledged problem, the NHTSA has concluded that it is not only unnecessary but inappropriate as well.

It is unnecessary because the ordinary private dealings between motor home manufacturers and their suppliers can ensure that sufficient technical information, experience with redesigned chassis, or some combination of the two will be available before the "primary" effective date. The legal requirement of compliance by vehicles built with chassis that are manufactured after that date can be expected to trigger those market forces which will induce suppliers of incomplete vehicles to cooperate with RVIA members. Any "experience interval" would represent an intrusion by the government into the satisfactory operation of those forces. This position was announced in the agency's response to an RVIA petition for reconsideration of effective dates (39 FR 40857, November 21, 1974) (copy enclosed).

The design of those motor homes that do not already comply with Standard No. 301-75 can be modified in many ways to achieve compliance. Changes might be made in both chassis and bodies. Bodies might be redesigned in such a way that no change in chassis construction is necessary. Conversely, all of the necessary protection might be incorporated in an upgraded chassis design, assuming that the addition of a motor home body did not present protrusions that would degrade this protection. In fact, this latter approach is already being followed in the case of school buses with a Gross Vehicle Weight Rating of more than 10,000 pounds. I understand that the School Bus Manufacturers Institute and several of its major chassis suppliers have reached agreements that provide for substantially all the necessary impact protection in the chassis.

While RVIA members may not be as successful as the schoolbus manufacturers have been in inducing their chassis suppliers to redesign for compliance, the above example illustrates the importance of the government's avoiding involvement in such contractual relationships. This agency is concerned in the first instance with the performance of completed vehicles, rather than the allocation between incomplete vehicle manufacturers and final-stage manufacturers of the task of redesigning for such performance. The agency lacks both the information and the expertise to determine either the most appropriate form of such redesign or the time that each manufacturer might consider desirable to effect the transition. This determination is therefore best made through cooperation or negotiation between the private parties involved. Because this determination is inextricably connected with decisions concerning the advance supply of redesigned chassis, it is impossible for the NHTSA to become involved in negotiations over the latter without interference in the former. The creation of an "experience interval" as requested by the RVIA would therefore be inappropriate. In any event, such a modification of the standard's effective dates is prohibited by Section 108 of the Motor Vehicle and Schoolbus Safety Amendments of 1974 (Pub. L. 93-492).

Finally, the NHTSA has not found it necessary to take special steps to encourage incomplete vehicle manufacturers to furnish advance information to motor home manufacturers. We understand that such cooperation is already taking place.

SINCERELY,

Congress of the United States House of Representatives

COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE

SUBCOMMITTEE ON CONSUMER PROTECTION AND FINANCE

April 21, 1976

James B. Gregory, Administrator National Highway Traffic Safety Administration Department of Transportation

The Recreational Vehicle Industry Association has contacted me regarding the Fuel System Integrity Standard (Standard 301) as it applies to manufacturers of motor homes. As you are aware, the first stage of the standard becomes effective on September 1, 1976.

It is my understanding that the Recreational Vehicle Industry Association has petitioned the NHTSA to delay the effective date of the Standard insofar as it applies to multi-stage vehicles. The Recreational Vehicle Industry Association maintains that motor home manufacturers should not have to comply with the new standard until they have received and had an opportunity to gain experience with the new complying incomplete vehicles. I can certainly appreciate the desire of NHTSA to see that the American motorist is provided the additional protection from Standard 301 as soon as possible, but I am also sympathetic to the difficulties which the motor home manufacturer may face.

I would appreciate your sending me any information you have explaining the NHTSA decision to deny the Recreational Vehicle Industry Association petition for an extension of time. Would you also please indicate what efforts, if any, NHTSA has made to see that chassis manufacturers supply the motor home manufacturers with information regarding the new complying chassis so that the second-stage manufacturer will be able to anticipate and plan necessary adjustments to insure that the completed vehicle also complies with the standard.

Thank you for your assistance.

Lionel Van Deerlin Chairman

ID: nht76-3.31

DATE: 06/30/76

FROM: JOHN WOMACK FOR FRANK BERNDT -- NHTSA

TO: FAM Enterprises

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your May 17, 1976, question whether special safety requirements exist for a vehicle that is modified to permit its operation by a handicapped person from a wheelchair that is secured at the driver's position.

Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (the Act) (15 U.S.C. @ 1397(a)(1)(A)) specifies that

@ 1397(a)(1) No person shall --

(A) manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment

unless it is in conformity with all applicable standards. If your modifications are made to a new vehicle prior to its first purchase for purposes other than resale and involve more than the addition of readily attachable components or minor finishing operations, Part 567 of our regulations requires that the vehicle remain in compliance following these alterations and that any change of gross vehicle weight rating or type classification be noted (49 CFR 567.7).

Assuming that the vehicle you modify is a multipurpose passenger vehicle under NHTSA regulations (e.g., a van-type vehicle that does not qualify as a truck) (49 CFR 571.3), it appears from your description of intended modifications that compliance with the following Federal motor vehicle safety standards might be affected:

Standard No. 101, Control Location, Identification, and Display

Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect

Standard No. 111, Rearview Mirrors

Standard No. 124, Accelerator Control Systems

Standard No. 206, Door Locks and Door Retention Components

Standard No. 208, Occupant Crash Protection

Standard No. 209, Seat Belt Assemblies

Standard No. 210, Seat Belt Assembly Anchorages

I have enclosed an information sheet that explains how to obtain copies of our standards and regulations.

There are no additional Federal motor vehicle safety requirements that apply to vehicles operated by a handicapped person sitting at the driver's position in a wheelchair. I have enclosed a Veterans Administration document detailing their specifications for vehicle modifications.

Exemptions from the motor vehicle safety standards are available only to manufacturers of motor vehicles in accordance with @ 123 of the Act (15 U.S.C. 1410).

FAM Enterprises

May 17, 1976

Department of Transportation

We are building a vehicle for the handicapped driver that is confined to a wheel chair. This vehicle is so designed that the driver may enter the vehicle by himself and operate all of the functions of this vehicle without leaving his wheelchair. Our intentions are to market this vehicle on a commercial basis.

Safety and complying with the present safety regulation is of great concern to us. Are there certain safety items that may be eliminated or need to be installed that are different from a normal driving vehicle? Safety catches will be installed to hold the chair in place in case of severe impact or an accident. If you feel that some items maybe changed, I would appreciate knowing of these prior to completing our first unit. We hope to have this in operation by the end of August, 1976. If some waivers are required, would you please put us in contact with the proper authorities so that we can take the necessary action to obtain these waivers.

Gary K. Mercer

ID: nht76-3.32

DATE: 04/02/76

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Hackney & Sons Inc.

COPYEE: BUREAU OF MOTOR CARRIER SAFETY

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of December 2, 1975, concerning the duties of a manufacturer of a beverage trailer that, when fully loaded, would overload a light-duty truck by which it might be towed.

The National Highway Traffic Safety Administration (NHTSA) does not directly regulate the use of motor vehicles. Instead, it regulates their manufacture, with a view towards their expected and intended uses. If a trailer manufacturer knows that his product is likely to be towed by a vehicle of insufficient load-carrying capacity, the NHTSA expects him to take reasonalbe steps, short of refraining from production, to minimize the likelihood of such misuse. Otherwise, the trailer would be considered to contain a defect relating to motor vehicle safety.

In the first hypothetical situation presented in your letter, there would be no violation of the Federal motor vehicle safety standards or regulations. In Situation 2, we are not prepared to state categorically whether or not the trailer manufacturer could be obliged to assume defect responsibility. Such responsibility might be minimized assuming that the written warning to which you refer clearly indicates (i) what load ratings are necessary as a minimum for the towing vehicle and (ii) that the trailer must not be towed by a vehicle without such load ratings. Nevertheless, the lines of responsibility between two such parties are not that clear-cut, especially where the trailer manufacturer knowingly delivers for introduction into interstate commerce a vehicle which immediately results in a serious overload situation.

In Situation 3, the trailer would probably contain a safety-related defect, because its advertising would promote its misuse in a way that would create a safety hazard. In Situation 4, the trailer would probably also be considered to contain a safety-related defect, because the total payload capacity could be calculated, and the warnings to limit the actual load to the limits of the towing vehicle could not reasonably be expected to be observed.

You have also asked more generally for a description of the circumstances under which trailers of this type might be considered to contain safety-related defects. The NHTSA cannot define in advance all such possible circumstances. Among them, however, would be those in which the owner's manual lacked the warning described above for Situation 2 and those in which the trailer's advertising promoted its misuse.

I have forwarded a copy of your letter to the Federal Highway Administration's Bureau of Motor Carrier Safety for examination of the possibility that the user of a mismatched combination of vehicles, if he is an interstate carrier, would be in violation of their regulations. There may also be State laws prohibiting local carriers from making such combinations.

Thank you for your concern for safety on the highways. We especially appreciate your realization that a manufacturer can have ethical duties that go beyond his legal duties.