ID: nht92-1.6

DATE: December 29, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Curtis J. Crist -- Product Development, US Marine

TITLE: None

ATTACHMT: Attached to letter dated 12/10/92 from Curtis J. Crist to Paul J. Rice (OCC 8136); Also attached to letter dated 10/8/76 from Frank Berndt (signature by Stephen P. Wood) to Donald I. Reed; Also attached to letter dated 12/21/77 from Joseph J. Levin, Jr. to Warren M. Heath

TEXT:

This responds to your letter of December 10, 1992, in which you ask for confirmation that the provisions of paragraph S4.3.1.3 of Motor Vehicle Safety Standard No. 108 relating to front side marker lamps for boat trailers remain unchanged from interpretations provided by this Office in 1976 and 1977.

I am pleased to confirm that these requirements remain the same. Paragraph S4.3.1.3, however, was renumbered S5.3.1.3 several years ago.

You have also asked as to what action you must take for elimination of the requirement for rear identification lamps on boat trailers 80 or more inches in overall width. You may file a petition for rulemaking requesting this change. I enclose a copy of 49 CFR Part 552, the regulation governing these petitions, which will advise you as to these procedures. Section 552.4 sets forth the information that the petition should contain, and the address to which it must be sent.

ID: nht94-2.49

TYPE: INTERPRETATION-NHTSA

DATE: April 19, 1994

FROM: S. Greiff -- PARS, Passive Ruckhaltesysteme GmbH

TO: Chief Counsel -- US Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached To Letter Dated 6/8/94 From John Womack To S. Greiff (A42; Std. 208)

TEXT: Per Fax: 001/202-366-3820

Your "Laboratory Test Procedure For FMVSS 208/212/219/301"

Gentleman:

PARS is a company developing occupant restraint systems for the world wide automotive industry. One of our major topics is the development of airbag systems.

For development and validation of the restraint systems we own a Barrier Impact Test Facility which was built up in 1993 new.

Our runway is 80 m (260 feet's) long. The velocity tolerance up to 60 kph is +/- 0.1 kph.

In your Laboratory Test Procedure for FMVSS testing, a minimum runway length of 500 feet is requested.

We would like to ask you for an interpretation of your "500 feet requirement".

It would be much appreciated, if we could get an answer by fax.

Our fax no. is: 01149/6023/942-133

Thank you very much for your efforts in advance.

Sincerely yours

ID: nht94-2.14

TYPE: Interpretation-NHTSA

DATE: April 1, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Eric T. Stewart -- Engineering Manager, Mid Bus (Lima, OH)

TITLE: None

ATTACHMT: Attached to letter dated 7/7/93 from John Womack to Thomas D. Turner; Also attached to letter dated 3/17/94 from Eric T. Stewart to Office of Chief Counsel, NHTSA (OCC 9792)

TEXT:

This responds to your letter of March 17, 1994, regarding a final rule published November 2, 1992 (57 FR 49413) amending Standard No. 217, Bus Emergency Exits and Window Retention and Release. You requested clarification of the width requirement in S5.5 .3(c) for retroreflective tape.

You are correct that there was a discrepancy concerning the size of the tape caused by the metric conversion in the final rule. Enclosed is a copy of a July 7, 1993 letter to Mr. Thomas D. Turner of the Blue Bird Body Company which discusses this issue. As explained in that letter, we plan to issue a correction notice of the November 2, 1992 rule that would specify a minimum size of 2.5 cm for the tape. Until the correction is issued, we will not take enforcement measures regarding tape size against a manufacturer who uses 1 inch wide retroreflective tape.

I hope you find this information helpful. If you have any other questions, please contact us at this address or by phone at (202) 366-2992.

ID: nht71-3.44

DATE: 07/21/71

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

TO: Peterson Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: In reply to your letter of July 9, you are correct in assuming "it will still be permissible to illuminate motorcycle license plates from the bottom even after January 1, 1973."

The installation requirements of Standard No. 108, as set out in SAE Standard 587d, License Plate Lamps, March 1969, do not apply to motorcycles and motor driven cycles.

ID: nht71-2.41

DATE: 05/05/71

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

TO: Jacob P. Billig, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of April 16, 1971, it is our opinion that the placement of the 2 1/4-inch-wide orange reflex reflector striping material on motor vehicles, in the manner shown in Exhibit A of your letter, would not impair the effectiveness of lamps, reflective devices, and associated equipment required by Federal Motor Vehicle Safety Standard No. 108, and would not be prohibited by that standard.

ID: aiam3433

Dear Ms. Avery: This is in response to your letter of November 11, 1980, concerning th application of the Federal odometer disclosure requirements. We regret our delay in responding. The answers to your specific questions are as follows:; 1. Are we required to give the purchaser an odometer statement in th states (such as Massachusetts, Pennsylvania, and Ohio) where the mileage at the time of the vehicle transfer is recorded on the Certificate of Title?; The odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may substitute the state certificate of title for the Federal odometer disclosure statement, if the state title contains essentially the same information found in the Federal statement. Where the state certificate of title can be substituted for the Federal form, there is no requirement that a separate Federal odometer disclosure statement be issued to the purchaser. However, if the information contained in the state certificate of title varies from that required in the Federal form, the state must obtain the approval of this agency before its certificate of title can be used as a substitute for the Federal form.; In order to spare states the burden of an approval process, the agenc has indicated that certain variations from the Federal form are acceptable. In the *Federal Register* notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1 notice, a copy of which is enclosed.; 2. If we sell a vehicle in Canada or Puerto Rico, is this la applicable?; For purposes of the Motor Vehicle Information and Cost Savings Act, a amended, 15 U.S.C. 1901 *et seq.*, Puerto Rico is a state. Therefore, the Federal odometer disclosure requirements are applicable to the sale of a vehicle in Puerto Rico. However, the agnecy has no jurisdiction over the sale of a vehicle in Canada.; 3. On the odometer statements, is the signature of the purchase required?; The Odometer Disclosure Requirements (49 CFR Part 580.4(e)) provid that the transferee (buyer) shall acknowledge receipt of the disclosure statement by signing it.; 4. If the vehicle is sold as salvage, are we required to give th purchaser an odometer statement?; The Federal odometer disclosure laws are not applicable to vehicle that are sold for salvage. The agency has determined that for purposes of the Federal odometer laws a vehicle is salvage if it is so badly damaged that it cannot be returned to the road. However, if the vehicle is repairable and will subsequently be used as a motor vehicle, disclosure has to be made.; Sincerely, David W. Allen, Assistant Chief Counsel

ID: nht73-1.38

DATE: NOVEMBER 23, 1973

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Mr. James C. Martin

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 9 to the U. S. Department of Transportation concerning the operation of 4-way flashers and brake lights on a 1972 Toyota.

Since there is no requirement that the hazard warning signal (4-way flashers) be capable of operating independently of the stop signal, it is permissible for the stop signal to override the hazard warning signal. In fact, these signals on most passenger cars and multipurpose passenger vehicles manufactured in the United States operate similarly.

ID: nht71-2.9

DATE: 02/18/71

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Bandag Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter to Mr. Hartman concerning the tire identification and record keeping regulation (49 CFR Part 574) requesting that you be allowed to code by pressure chamber rather than by matrix.

Since the pressure chamber is used by Bandag to serve a purpose similar to the purpose served by the matrix in hot processing of retreaded tires, you may assign(Illegible Word) numbers to your pressure chambers and use this code number in place of the matrix code number required by Part 574.

ID: nht90-1.47

TYPE: INTERPRETATION-NHTSA

DATE: FEBRUARY 19, 1990

FROM: ANTHONY T. GREENISH -- U.N.D.P.

TO: U.S. DEPT. OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-25-90 TO ANTHONY P. GREENISH FROM STEPHEN P. WOOD; (A35; PART 591) TEXT:

I am presently contemplating purchasing a car in Europe and importing it when I return to the United States in July 1990. The two models I have in mind are:

1. The BMW model 324 d Diesel

2. The Honda model Accord 1.6 Ix

Any information you can provide as to how these cars rate as to motor vehicle safety standards would be very welcome.

ID: 0596

Mr. Michael A. Holmes
#503768, 7B10
Farmington Correctional Center
1012 West Columbia
Farmington, MO 63640-2902

Dear Mr. Holmes:

This responds to your letter of December 6, 1994, to the Secretary of Transportation, regarding the laws that apply to the manufacture of cars and light trucks. You have a design which you describe as "hydrogen turbine over electric."

The principal law that the Department of Transportation administers that pertains to the construction of motor vehicles is Title 49 United States Code Chapter 301 - Motor Vehicle Safety. Under its authority, we have issued the Federal Motor Vehicle Safety Standards and other pertinent regulations. These are available from the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402 at an invoiced cost of around $25. The title of the volume you want is "49 CFR Parts 400-999"; all our regulations are in the 500 series. The Safety Standards are at Part 571. The applicability section of each standard informs the reader as to the types of vehicles to which it applies, such as passenger cars, motorcycles, etc. However, the standards don't differentiate between propulsion sources, and there are no standards that apply to "electric vehicles," or, in your case, "hydrogen turbine over electric."

You should be aware that the Environmental Protection Agency establishes standards for motor vehicle emissions, and that the individual States are permitted to have their own standards in areas where the Department of Transportation has not acted, such as horns and fog lamps.

If you have any further questions, they should be directed to this Office and we will be pleased to answer them.

Sincerely,

Philip R. Recht Chief Counsel ref:571 d:1/11/95