ID: nht76-1.29

DATE: 12/01/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Pirelli Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your November 1, 1976, letter to Mark Schwimmer of my staff, concerning the marking "V1" on passenger car tires.

The marking "V1" is not required by any Federal statute, motor vehicle safety standard, or other regulation to appear on the sidewall of passenger car tires. Furthermore, Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 as amended, 15 U.S.C. 1392(d), provides in pertinent part:

Whenever a Federal motor vehicle safety standard establshed under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard.

This provision, considered with Federal Motor Vehicle Safety Standard No. 109, prohibits any State from imposing any safety labeling requirements for passenger car tires other than those contained in that standard. Any differing safety labeling requirements, including the "V1" that you have mentioned, are thus preempted and void.

SINCERELY,

NOVEMBER 1, 1976

Mark Schwimmer N.H.T.S.A. Office of Chief Counsel

The marking V1 on passenger car tires, as you know, signifies compliance to the "minimum performance requirements and uniform test procedures for new tires for passenger cars and station wagons" issued by the Vehicle Equipment Safety Commission on May 14, 1965 and later revised on October 11, 1965 and September 17, 1966.

To my knowledge no further revisions have been made, because the FMVSS 109 went into effect as of January 1, 1968. I assume, therefore, that the marking V1 should be applied only on the tires listed in the tables 1 - 6 of the regulation as follows: Table 1 - Domestic bias tires of the following series: Low Section (ex. 6.50-14) 4 & 8 P.R.

Super Balloon (ex. 6.70-15) 4 & 8 P.R.

Super Low Section (ex. 6.95-14) 4 & 8 P.R.

Table 2 - 70 Series, alpha numeric bias construction (ex. E 70-14) Table 3 - Domestic radial millimetric series from cross section Table 4 - European bias tires of the following series: Table 5 - European bias tires of the millimetric series (ex.

Table 6 - European radial tires of the millimetric series up to the cross section 155 (ex. 145 R 13) version A (32 psi)

I would like to know if the above is correct and therefore the marking V1 is no longer requested on the tires not included in this list.

If the requirements do not apply to every state in the United States, please notify me.

Thank you in advance for your reply on this matter.

PIRELLI TIRE CORPORATION

Galileo Buzzi-Ferraris Technical Manager

ID: nht88-2.81

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: ROBERT G. YORKS -- VICE PRESIDENT AND GENERAL MANAGER, AUTOMOTIVE BUSINESS GROUP, TRUCK-LITTLE CO.

TITLE: NONE

ATTACHMT: MEMO DATED 5-24-88, TO KATHLEEN DEMETER, FROM ROBERT G. YORKS, 25220; MEMO UNDATED, TO ROBERT G. YORKS, FROM KATHLEEN DEMETER

TEXT: We have received your letter of May 24, 1988, withdrawing your request for confidential treatment of your letter of March 31 concerning the legality of a new safety lighting device. This letter also responds to your inquiry of July 14.

The device is described as a "combination center high-mounted stop lamp and cargo lamp". The functions are optically separate. The cargo lamp can illuminate the cargo box on pick-up trucks, while on vans and utility vehicles it serves as a "utility lig ht". The device is intended to be used as either original or aftermarket equipment.

The Federal motor vehicle safety standard on vehicle lighting is Standard No. 108. As you know, the center high-mounted stop lamp is required only for passenger cars. Further, there is no requirement that a center lamp intended for other types of motor vehicles meet the passenger car lamp requirements (for example, those requirements would prohibit combining the center lamp with the cargo lamp). As neither function of your device is required on lighting equipment for vehicles other than passenger car s, Standard No. 108 permits the installation of your device as original equipment provided that it does not impair the effectiveness of the lighting equipment that the standard does require. Whether impairment exists is initially a determination of the manufacturer of the vehicle who certifies compliance with Standard No. 108. However, the issue of impairment is ultimately subject to a determination by this agency. Types of impairment that can exist include functional interference with the wiring of o ther lamps, creation of ambiguous or confusing signals to such a degree that it may obscure the message of lamps and reflectors required by Standard No. 108, and reduction of photometrics below the minimum levels specified.

As an item of aftermarket lighting equipment, it is subject to a restriction of the National Traffic and Motor Vehicle Safety Act that its installation by a manufacturer, dealer, distributor, or motor vehicle repair business must not render inoperative i n whole or in part any device or element of design installed in accordance with a Federal motor

vehicle safety standard. We construe this prohibition strictly and equate it with impairment. If performance is "impaired," it can be viewed as "inoperative" with respect to achieving the purpose for which it has been installed.

Assuming that installation of an aftermarket device is not restricted by the Act, it nevertheless remains subject to the laws of a State in which the vehicle is registered and driven. We are not conversant with State laws on combination rear lamps, but you may wish to consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, for an opinion.

I hope that this answers your questions.

ID: 1985-03.25

TYPE: INTERPRETATION-NHTSA

DATE: 08/06/85

FROM: AUTHOR UNAVAILABLE; Mr. William Pesce; NHTSA

TO: Mr. William Pesce

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your May 18, 1985 letter inquiring about the existence of any Federal safety requirements applicable to your projected sale of colored windshield wiper blades.

Under the National Traffic and Motor Vehicle Safety Act, this agency has issued Federal Motor Vehicle Safety Standard No. 104, Windshield Wiping and Washing Systems, applicable to new motor vehicles. While this standard does not regulate wiper color, it does, among other things, require that a wiping system clear a minimum percentage of a vehicle's windshield.

In addition, Standard No. 107, Reflecting Surfaces, also applies to new motor vehicles. This standard specifies reflecting surface requirements for certain components, including windshield wiper blades, in the driver's field of view. Its purpose is to reduce the likelihood that unacceptable glare from reflecting surfaces will hinder safe and normal operation of the vehicle.

If a new vehicle equipped with your blade did not comply with Standard No. 104 or Standard No. 107 due to some aspect of that blade, the sale of that car to the public would be a violation of the prohibition in section 108(a)(1) (A) of the Act against the sale of noncomplying vehicles.

As to used vehicles, you should be aware that section 108(a)(2)(A) of the Act prohibits manufacturers, distributors, dealers and vehicle repair businesses from knowingly rendering inoperative equipment or elements of design installed on a vehicle under Federal motor vehicle safety standards. Care should be taken that the installation of your product would not have that effect. A rendering inoperative might occur if, for example, your blade were not large enough to enable the wiping system to clear a sufficient area of the windshield. We urge you therefore to ensure that the substitution of your blade for an original equipment blade provided by a vehicle manufacturer would enable the wiping system to continue to perform as required by Standard No. 104, and would not produce unacceptable glare in the driver's field of view, as required by Standard No. 107.

I hope this information is helpful.

ENCLS.

OCC-0747

Department of Transportation

May 18, 1985 We propose to offer for sale to the public a colored windshield wiper blade.

Our blade attaches to existing windshield wiper arms.

It does not alter in any way the speed or rythem of an operating wondshield wiper.

It is not made of floresent, or as they are called HOT colors nor is it reflective in any way.

We have been unable to find any safty restrictions which would apply to our product. If such restriction do, or do not exist we would appreciate receiving this information by return mail in the envelope provided.

William Pesce B P Origionals

ID: 21012.ztv

Brandon Billingsley, Vice President Marketing
CRS Electronics
Heavy Duty Bus Parts
17850 I-45
Willis, TX 77318

Dear Mr. Billingsley:

We are replying to your letter of November 19, 1999, with respect to your "new overhead LED warning light system for school buses." You ask whether your product will comply with Federal standards.

You call the new technology "strobing LEDs," and say that you are able to "build a warning light module that combines the 'attention grabbing,' authoritative effect of strobe lights and the long life expectancy of LEDs." You have tested "according to the protocols of SAE J887," and report that your product "does indeed exceed the requirements of SAE J887 for strobe lights."

We assume that you wish to offer your product as original equipment on school buses. The acceptability of your product is determined by Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. Paragraph S5.1.4 of Standard No. 108 requires each school bus to be equipped with a system of four red signal (or four red and four amber) lamps designed to conform to SAE Standard J887, July 1964. Under this standard, school bus warning system lamps are required to flash alternately in a range of 60 to 120 flashes a minute. Unlike later versions of J887, an optional flash rate in Hz is not specified.

A few years ago we were asked whether a school bus warning system consisting of strobe lights met Standard No. 108. I enclose a copy of our letter of March 29, 1994, to Harry C. Gough. The system we were asked about was described as flashing "on and off four times in a 255 millisecond period and then stays off for 745 milliseconds, then the lamp on the opposite side of the vehicle repeats the aforementioned pattern." We replied that we believed that the light emanating from a strobe lamp under these performance parameters "will be perceived as a single flash of varying intensity and not as four separate flashes, and that when this is followed by an identical pattern on the other side of the bus, the system is one that is alternatively flashing within the meaning of Standard No. 108."

You did not specify the flash rate of your product, but you may use our 1994 interpretation as a guideline for determining whether the light would be perceived "as a single light of varying intensity," and hence compliant with Standard No. 108. If it would not be so perceived, then your lamps would appear to be noncompliant with the Standard's requirements.

The minimum photometric requirements of the 1964 specification are also the ones that apply to your product. I enclose a copy for your information.

If you have questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref:108
d.2/29/2000

ID: GF005899

Ms. Robin C. DesCamp
Blount International, Inc.
PO Box 22127
Portland , OR 97269-2127

Dear Ms. DesCamp:

            This responds to your August 26, 2004, letter and subsequent e-mail to George Feygin of my staff. You ask whether various items manufactured by your company for logging purposes would be classified as “motor vehicles” and subject to the agency’s early warning reporting (EWR) regulations (set forth in 49 CFR Part 579) or to our vehicle identification number (VIN) requirements (49 CFR Part 565).  As explained below, based on the information you provided, we do not consider the items to be motor vehicles for the purposes of our regulations. Thus, the EWR and VIN requirements do not apply.

           Title 49 U.S.C Chapter 301 authorizes the National Highway Traffic Safety Administration (NHTSA) to prescribe Federal motor vehicle safety standards (FMVSSs) applicable to new motor vehicles and new items of motor vehicle equipment. Section 30102(a)(6) defines “motor vehicle” as:

“[A] vehicle driven or drawn by mechanical power and manufactured primarily for use on the public streets, roads, and highways, but does not include a vehicle operated only on a rail line.”

NHTSA has issued several interpretations of this language. We have stated that vehicles equipped with tracks, agricultural equipment, and other vehicles incapable of highway travel are not motor vehicles. We have also determined that certain vehicles designed and sold solely for off-road use (e.g., airport runway vehicles and underground mining vehicles) are not motor vehicles, even if they may be operationally capable of highway travel. Finally, we have concluded that items of mobile construction equipment that use the highways only to move between job sites and that typically spend extended periods of time at a single site are not motor vehicles. However, we do consider vehicles that use the public roads on a necessary and recurring basis to be motor vehicles.

In the present case, the information you have provided describes specialized cranes and loaders made for delimbing and loading logs. Although the cranes are equipped with wheels, the pictures and the description of the logging cranes indicate that they are intended to remain at a single location for prolonged periods of time. Your letter confirms that these cranes are moved only infrequently between logging sites.

Based on this information, it appears that the logging cranes are akin to airport runway vehicles or items of mobile construction equipment that do not travel on highways on a recurring basis. Accordingly, we find that the logging cranes described in your letter are not “motor vehicles.” Because these machines are not motor vehicles, they are not subject to our regulations and requirements, including those of the EWR and VIN programs. 

I hope you find this information helpful.  If you have any other questions please contact Mr. George Feygin at (202) 366-2992.

Sincerely,

Jacqueline Glassman

Chief Counsel

ref:571

d.11/5/04

ID: 8073-1

Mr. Ron Marion
Sales Engineer
Thomas Built Buses, Inc.
P.O. Box 2450
1408 Courtesy Road
High Point, NC 27261

Dear Mr. Marion:

This responds to your letter asking whether there has been any consideration given to excluding "non-route-type" school buses from Standard No. 131's requirement that school buses be equipped with a stop signal arm. You stated that, as a manufacturer of school bus bodies, you are getting numerous questions regarding the installation of stop arms on school buses not used on route service. According to your letter, a number of schools across the U.S. purchase school buses, paint them a color other than yellow, and use them exclusively for athletic trips. You stated that these buses pick up at the school and travel to another school to unload, and do not make stops for loading or unloading along the way and in no way attempt to control traffic. You stated that the purchasers of these school buses are concerned about paying for stop arms which are never used.

As you know, Federal Motor Vehicle Safety Standard No. 131, School Bus Pedestrian Safety Devices, is a new Federal motor vehicle safety standard which requires all new school buses to be equipped with a stop signal arm. The purpose of the requirement is to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the bus.

To answer your specific question, this agency has not considered whether "non-route-type" school buses should be excluded from Standard No. 131's requirement for a stop signal arm. I note that this issue was not raised in the comments on our notice of proposed rulemaking.

We do appreciate the concern of a purchaser about paying for safety equipment that he or she believes will never be used. However, the limited information provided in your letter does not provide a basis for concluding that we should consider changing the standard.

We do not know how many school buses are used exclusively or primarily for "non-route-type" service, although we assume the number is small. Further, it would appear that there would be occasion to use stop signal arms for some school buses used for such service. For example, these safety devices might be used while loading and unloading students when the school bus is parked on a school driveway or a road near a school, if the school bus is used to transport students to activities at locations other than schools, or if the school bus is sometimes used as a replacement for out-of-service regular route school buses. I also note that, assuming that there is occasion to use stop signal arms for some school buses which are primarily used for non-route service, it is not clear how the agency would distinguish, for purposes of a regulation, which school buses should be excluded from the requirement for stop arms.

I hope this information is helpful.

Sincerely,

Barry Felrice Associate Administrator for Rulemaking

ref:131 d:3/3/93

ID: 2523y

The Honorable Lawrence J. Smith
U. S. House of Representatives
Washington, D.C. 20515

Dear Mr. Smith:

I am writing in response to your letter forwarding correspondence from your constituent, Mr. Joel Leitson, with respect to litigation recently brought by the United States against several firms that install plastic film, or "tint," on automobile windows.

You have asked about the statutory authority under which these suits were brought. Pursuant to section 103 of the National Traffic and Motor Vehicle Safety Act of 1966 ("Safety Act"), 15 U.S.C. 1392, the National Highway Traffic Safety Administration ("NHTSA") has issued safety standards applicable to new motor vehicles and items of motor vehicle equipment. One of the standards that we have issued under this authority is Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR 571.205), which applies to all new vehicles and all new glazing materials for use in motor vehicles. Among the requirements set forth in Standard No. 205 are specifications for minimum levels of light transmittance (70 percent light transmittance in areas requisite for driving visibility, which includes all windows in passenger cars).

Section 108(a)(i)(A) of the Safety Act, 15 U.S.C. 1397(a)(1)(A), provides that no person may manufacture or sell any vehicle unless it is in conformity with all applicable safety standards. Pursuant to section 108(b)(1) of the Safety Act, 15 U.S.C. 1397(b)(1), this paragraph does not apply after a vehicle is first sold to a consumer. However, both before and after the first sale, section 108(a)(2) of the Safety Act, 15 U.S.C. 1397(a)(2), provides that "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . ."

Thus, by installing tint film on automobiles that reduces the light transmittance of their glass below 70 percent, the firms in question have been rendering those vehicles "inoperative," in violation of the Safety Act. The same principle would apply to a service station that removed an airbag or a safety belt from a vehicle, since such an action would create a noncompliance with the occupant protection requirements of NHTSA's standards.

You also asked for our comments on whether Florida's statutes are preempted by these suits. We assume that you are referring to the provision of Florida law that prohibits the operation of any vehicle in the State of Florida that has glazing with less than 35 percent light transmittance. This statute, and similar statutes adopted by other states, do not purport to legitimize conduct -- the rendering inoperative of glazing by tint installation firms -- that is illegal under the Safety Act. Thus, there is no conflict with Federal law, and Florida may continue to enforce its operating rules.

I hope that this responds to your questions. If we can be of further assistance, please let me know.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:205#VSA d:6/25/90

ID: 77-1.23

TYPE: INTERPRETATION-NHTSA

DATE: 02/15/77

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Oconomowoc Public Schools; Wisconsin

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 3, 1977, letter asking whether the new school bus definition (effective April 1, 1977) precludes the use of vans which seat less than 10 passengers from transporting children to and from school.

The Motor Vehicle and Schoolbus Safety Amendments of 1974 (Pub. L. 93-492) authorized the NHTSA to redefine the term "school bus" to include all motor vehicles which seat 10 or more passengers and which transport children to and from school. The NHTSA redefined the term in accordance with the wishes of Congress for the purpose of prescribing safety requirements for buses that fall within the definition. The definition does not preclude the use of vans or any other type of motor vehicle which seat fewer than 10 passengers from transporting children to and from school. Such vehicles may transport children without complying with the school bus safety requirements.

SINCERELY,

Oconomowoc Public Schools

February 3, 1977

Charles E. Duke Deputy Administrator NHTSA

Members of the Wisconsin Legislature are attempting to define a school bus to allow some flexibility for vehicle use in the under 10 passenger capacity. Senate Bill 110 was introduced on Wednesday, February 2, 1977 with the leaders attempting to push it through without opposition. The bill has many fine features with only one specific area of concern on the part o school administrators.

In place of using the term "vehicles under 10 passengers," the author stated specifically "an automobile or station wagon that is not designed or constructed as a van" may be used. This is for transportation other than transportation of children to or from school. The proponents for this measure claim the new federal regulation to be enacted on April 1, 1977 will require all states to conform to this measure. Since many schools have small vans for use in lunch delivery, mail service, and the like, they find these vehicles very useful in transporting small groups like the golf team, forensic students, and band groups and at a minimum cost.

I am enclosing the portion of Bill 110 that pertains to vehicle on use of the description. Please review the measure and provide a ruling term "vehicles under 10 passengers" in place of "an automobile or station wagon that is not designed or constructed as a van" with reference to the new federal regulation.

The chairman of the review board on legislative measures stated yesterday that he felt a hearing on Bill 110 would be held by February 15, 1977. I realize the request is on short notice but also realize that without some interpretation from your agency, we will be forced to live with a measure that will be very costly and inefficient.

Thank you for your help and assistance.

Carlyle Holtan Director of Transportation

[ENC. OMITTED]

ID: 2953o

Mr. George Ziolo
DOT Paperwork Processor
234l7 Everett Place
Ramona, CA 92065

Dear Mr. Ziolo:

This is in reply to your letter of April 20, 1988, asking about the acceptability under Safety Standard No. l08 of modifying imported vehicles so that they are equipped with two Type 2D1 and two Type 1C1 headlamps. You have been informed by the agency's Office of Vehicle Safety Compliance that this is impermissible "because they are 'nonconforming' 'headlight systems'." You disagree because you believe that the minimum requirements of the Standard are satisfied by the Type 2D1 lamps, and that "S4.4 appears to permit such a combination."

Paragraph S4.4 is not applicable to the situation you present as it refers to combinations of lamps serving different functions; in your discussion, the lamps serve the identical function of headlighting. Given the fact that the Type 2D1 sealed beam 7" diameter headlamps fulfill the headlighting requirements of the Standard, your question must be viewed as whether a supplement to the headlighting system is permissible under Standard No. l08.

Paragraph S4.l.3 of Standard No. l08 permits the addition of nonrequired lighting equipment provided it does not impair the effectiveness of the equipment that the standard requires. The two Type 1C1 5 3/4" diameter sealed beam lamps in a four lamp headlighting system form the major portion of an upper beam headlighting system. The two Type 2D1 lamps in a two lamp headlighting system form the whole of an upper beam headlighting system. Thus, a vehicle furnished with the systems you posit would be equipped with more than one upper beam headlighting system. The Type 2D1 system must be designed to conform to the photometric requirements of SAE Standard J579c DEC79 "Sealed Beam Headlamp Units for Motor Vehicles." The SAE Standard establishes at two test points, H-V and 4 D-V, maximum allowable candela of 75,000 and 5,000 respectively for each Type 2D1 headlamp. This means that the maximum allowable candela for headlighting systems at these test points is 150,000 and l0,000 candela. The Type 1C1 headlamps will also be designed to conform to SAE J579c. Corresponding maxima at test points H-V and 4 D-V for Type 1C1 systems are 60,000 and 5,000. Thus, a vehicle equipped with the lamps you have described could emit a total of 270,000 candela at test point H-V (when only 150,000 is permitted), and 20,000 at 4D-V (when only l0,000 is allowable).

Agency research has shown that candela readings in excess of 150,000 greatly increase the potential for glare with little increase in seeing ability. This glare would be visible both to the driver of an oncoming car, and the driver of the modified vehicle itself through creation of a "veiling" glare. The addition of the Type 1C1 headlamps would therefore impair the effectiveness of the Type 2D1 headlighting system, and is forbidden by S4.1.3.

We appreciate your interest in safety.

Sincerely,

Erika Z. Jones Chief Counsel

ref:108 d:9/12/88

ID: 2984yy

Eric G. Hoffman, Esq.
Russell & Hoffman, Inc.
2000 NCNB Plaza
300 Convent Street
San Antonio, Texas 78205-3793

Dear Mr. Hoffman:

This responds to your letter of March 26, 1991, addressed to Mr. Harry Thompson, asking about a private school's use of "mini-vans which are designed to carry more than 10 passengers." Your letter was referred to our office for reply. You stated that the school has become aware of the National Traffic and Motor Vehicle Safety Act (Safety Act) and is concerned whether the operation of the vans is in compliance with applicable regulations under the Act. You asked a number of questions related to that concern.

I am pleased to have this opportunity to clarify the operation of Federal law as it applies to school buses. The National Highway Traffic Safety Administration (NHTSA) defines "school bus" as a motor vehicle designed for carrying 11 or more persons, including a driver, and sold for transporting students to and from school or school-related events. Therefore, the vehicles refered to in your letter would be considered school buses under federal law.

The National Highway Traffic Safety Administration (NHTSA) has issued Federal motor vehicle safety standards applicable to all new school buses. These standards impose obligations on the manufacturers and sellers of new motor vehicles, not upon the subsequent users of these vehicles. It is a violation of Federal law for any person to sell as a school bus any new vehicle that does not comply with all school bus safety standards. If your client believes that they have been sold noncomplying vehicles, and that the dealer knew of their intended use, the school should contact NHTSA's Office of Vehicle Safety Compliance, at the address given above, and inform them of the apparent violation of Federal law.

Without violating any provision of Federal law, a school may use a vehicle to transport school children, even if the vehicle does not comply with Federal school bus regulations. This is so because the individual States have authority over the activities of a user of a school bus. Since the various questions you ask assume that the Safety Act regulates users of school buses, we are unable to provide specific answers to those questions. To determine whether the private school your firm represents may use noncomplying vans, you must look to state law.

I must emphasize NHTSA's position that a vehicle meeting Federal school bus regulations is the safest way to transport students. I encourage the school your firm represents to give its most careful consideration to the possible consequences of transporting students in vehicles that do not comply with these regulations.

I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:571.3 "school bus" d:4/29/9l