ID: nht91-1.9

DATE: January 3, 1991

FROM: Jim Holperin -- State Representative, 34th Assembly District

TO: Taylor Vinson -- Legal Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2-26-91 from Paul Jackson Rice to Jim Holperin (A37; Std. 108)

TEXT:

I write today on behalf of LeRoy E. Mueller, President of the Wisconsin Trailer Company, Inc. in Phelps, Wisconsin. Mr. Mueller's company recently submitted a bid to the Wisconsin Department of Natural Resources for two tilt-deck trailers based on the enclosed specifications.

As Mr. Mueller is concerned that if he builds the trailers exactly to specifications that they will be in violation of Title 49, Section 571-108 and, by cross reference, in violation of relevant SAE requirements.

Kevin Cavey recommended I direct this correspondence to you and request a determination from the NHTSA regarding whether our DNR's trailer specifications comply with Title 49 and relevant SAE codes. I am also enclosing a letter from Mr. Mueller indicating his primary concern lies with what appears from the specifications to be a permanent, stationary ramp which Mr. Mueller believes might obscure a clear view of the trailer's tail lights from a 45 degree angle as required by Title 49 and SAE codes.

I would appreciate it if you could take time to review the enclosed material and determine whether Mr. Mueller's concerns regarding an obstructed view of the tail light are legitimate or not. Thank you for giving this request your consideration and, of course, if there is additional information you need please do not hesitate to contact me by letter or phone.

Attached to a map of the 34th Assembly District (Text omitted)

Attachment Specification 8 SPECIFICATION

TYPE: (2) Two 26,000 lb. minimum payload capacity "over the wheel" tilting platform trailer.

DELIVERY: The successful bidder shall deliver all units ordered, after final inspection and approval by DNR personnel, to DNR, Neil H. LeMay Forestry Center, 518 West Somo Ave., Tomahawk, WI 54487, and to arrive during regular working hours - Monday thru Friday, 7:45 a.m. to 11:45 a.m. and 12:30 p.m. to 4:30 p.m. Advance notice of at least one day shall be given. The successful bidder shall arrange for and pay transportation costs for the delivery of all units ordered.

USE: Trailer will be used to transport medium sized crawler tractors with fire plows, heavy duty wheel tractors, and farm-type machinery, both on and off the road, maximum highway speed will be 55 MPH.

A. CAPACITY: 26,000 lb. minimum payload capacity. When unloaded, there shall be sufficient tongue weight to enable the unit to be towed without fish-tailing.

OUTLINE DRAWING - T-D169-401 Issue 02

B. PLATFORM: Length - 20 feet Width - 94" minimum - 96" maximum Height - 38" maximum fully loaded

FRAME: Steel shall be designed with ample safety factor and electrically welded where steel meets steel. All crossmembers are to be in line, fully welded on top, sides, and bottom, both on the inside and outside of the main frame.

DECK: Full 2 inch thick treated apitong wood deck. The entire rear 7 feet of the trailer to be ribbed traction bed with 3.75" x 2" x 3" angle steel ribs replacing the wood deck planking. Ribs to be spaced 7" on center with the 3" leg facing the front of the trailer. All wheel well openings shall be covered. Area around wheel wells shall be reinforced to support deck.

ANGLE IRON LOADING GUIDES: Locate three removable angle iron guides on top of deck per outline drawing.

Stake pockets, footholds, expanded metal walkway, tie-down slots per outline drawing.

LOADING RAMPS: 0.50" thick steel formed loading ramps per outline drawing.

PLATFORM LOCK: Shall be heavy duty screw type, self adjusting for wear, and shall hold the platform tight and rattle free in the closed position, The end of the screw shall be wedge shaped for ease of engagement.

OPERATION: Deck to tilt open or closed with 150 lb. weight, allowing loading or unloading of equipment. Loading angle shall not exceed 15 degree incline. Zerk type grease fittings shall be on all platform tilt pivot points.

SPECIFICATION

CUSHIONING DEVICE: One (1) 4" hydraulic cylinder with 1.25" diameter rod, or two (2) 2.5" hydraulic cylinders with 1" diameter rod (all minimum dimensions) designed to cushion the opening and closing the platform. When cylinders are completely open, the bed of trailer shall be capable of tilting 4" minimum below ground level in the tiltbed position.

C. SUSPENSION: Single point spring suspension - Neway USR 444, or equal - able to maintain equal ground pressure while traveling over uneven terrain.

AXLE LOCATION: Distance from center of axles to front of trailer bed to be approximately 10 feet.

TIRES: Nine (9) 7.5 x 15 L.R. "F" (12PR) low platform trailer tube type tires and rims capable of meeting load and speed requirements of this specification as noted in item A. One (1) tire to be mounted on spare rim. Valve extensions required on inside tires.

WHEEL: Budd disc wheels. Stemco oil wheel seals shall be furnished on all axles.

AXLES: Full width through type axles with one (1) hubometer.

D. BRAKES: Full air complete with all lines, breakaway control valve, and air reservoir tank with 1,000 cubic inch minimum capacity. Air brake hoses to extend a minimum of 24" ahead of the pintle eye and shall be complete with couplings. Air lines shall not be interchangeable. Left gladhand shall be the emergency air line Velvac #55B-13. Right hand gladhand shall be the service air line Velvac #55B-14. Brake system shall meet SAE and DOT requirements. All wheel brakes to be 12.25" x 7.5" minimum. Gladhand holders are required for brake lines when they are not in use, and are to be mounted near tongue. Include piggy back parking with mechanical release and mechanical release tool.

E. ELECTRICAL SYSTEM: Shall be per writing diagram T-AO86-701 furnished as a part of this specification.

WIRING: Shall meet all SAE, ICC, and DOT requirements. All wires shall be in loom, heavy jacket, or conduit and mounted in a protected position. Where wires pass through steel, they shall be protected with rubber grommets. Two (2) feet of conductor wire, ahead of pintle, shall be installed in the female plug for connection to the towing vehicle. No aluminum rivets for grounds are allowed.

LIGHTS: Lights shall meet SAE, ICC, and DOT requirements. Lights shall be in protected recesses or with protective base around lights. All lights shall be of the plug-in type.

SIX POLE PLUG: Vel Vac #59P-6 (6 way male plug) with replaceable interior, or equal.

Attached to drawings and photos of Lid Trailer (Text and graphics omitted)

ID: nht91-2.1

DATE: February 26, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Lennard S. Loewentritt -- Deputy Associate General Counsel, Personal Property Division, General Services Administration

TITLE: None

ATTACHMT: Attached to letter dated 11-7-90 from Lennard S. Loewentritt to Paul Jackson Rice (OCC 5432)

TEXT:

This responds to your November 7, 1990 letter requesting further clarification with regard to my August 23, 1990 letter to you. 49 CFR S571.7(c) provides that Federal motor vehicle safety standards do not apply "to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications. In my August letter, I stated that school buses purchased by the General Services Administration (GSA) for the sole use of the Army would be considered to fall within this exception. This interpretation was based on the assumption that GSA acts as a purchasing agent for the Army.

In your recent letter, you stated that this assumption was erroneous. While GSA's Automotive center does act as a purchasing agent for some agencies, the vehicles in question would be purchased for the GSA'S Interagency Fleet Management System (IFMS). Vehicles in the IFMS "are assigned on an indefinite basis to agencies that have had their fleets consolidated into the IFMS." You stated that the Army has consolidated their nontactical vehicles into the IFMS.

In this case then, the GSA would be purchasing buses which are intended for "indefinite assignment to and sole use by the Army for the purpose of transporting troops as well as transporting military dependents to and from school." You stated that these vehicles would be manufactured in conformity with contractual specifications "which reflect the requirements of the Federal Motor Vehicle safety standards for buses rather than school bus specifications." Given this clarification of GSA's role, you again asked if these buses would fall within the exception in 49 CFR 571.7(c).

The answer to your question would be yes, if the purchase contract specifies that the buses should not be certified as school buses in order to serve the needs of the Armed Forces. In these circumstances, we see no meaningful difference between a sale directly to an element of the Armed Forces and a sale to GSA's IFMS intended for exclusive and indefinite assignment to the Army. In announcing this conclusion, I want to make several points. In the interest of safety, I strongly recommend that the contract specify compliance with the substantive provisions of the Federal motor vehicle safety standards relating to school buses, except insofar as they are actually inconsistent with the intended use of the bus. Also, if reassignment of these buses to another agency is ever contemplated, I would appreciate your undertaking to ensure that they would only be used for transporting adults.

I hope this response is helpful. Please let me know if you have any further questions or need any additional information.

ID: nht91-2.10

DATE: March 6, 1991

FROM: Earl C. Lempke -- President, Delavan Industries Inc.

TO: Taylor Vinson -- NHTSA (Dot)

TITLE: None

ATTACHMT: Attached to letter dated 3-27-91 from Paul Jackson Rice to Earl C. Lempke (A37; VSA 1392(d); Std. 108)

TEXT:

You have been referred to us by Truck Lite Corporation as their contact with the Government concerning Trailer Lighting.

Delavan is the major Manufacturer of Automobile Transport Trailers and have been building this equipment for forty-five years.

Our question, is there any federal ruling stating that Trailer Clearance Lights are considered as Safety Equipment and as such are not to be included as part of the overall width of the vehicle?

Believe it or not, Truck Lite has nothing they can refer to us to substantiate this. Is there any ruling on this matter which you could send us?

Thank you for your help and please call me (800-258-2528) if you need any more information.

Attachment Copy of Federal Highway Administration Federal Motor Safety Regulations dated January, 1990, regarding S393.19 - S393.22, page 184. (Text omitted)

ID: nht91-2.11

DATE: March 6, 1991

FROM: Gregory J. Vonderheide -- Markets Unlimited Group, Inc.

TO: NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3-29-91 from Paul Jackson Rice to Gregory J. Vonderheide (A37; Std. 108)

TEXT:

Could you please forward to me the application(s) neccessary for the Department of Transportations approval of a new product.

The product is a Safety Light for motor vehicles, commercial trucks and bicycles.

Thank you.

ID: nht91-2.12

DATE: March 6, 1991

FROM: Mark A. Pacheco -- Vice President, Innovative Industries of Tampa, Inc.

TO: Department of Transportation, NHDSA

TITLE: Re Subj: Ruling on Motorized Scooter

ATTACHMT: Attached to letter dated 4-1-91 from Paul Jackson Rice to Mark A. Pacheco (A37; VSA S 102(3))

TEXT:

On behalf of our client Walk Machine Corporation, 17690 South Dixie Hwy (US-1), Miami, FL 33157, Florida USA. We would like to obtain a ruling from you regarding their "Walk Machine". Attached for your reference is a brochure on the product.

These are being manufactured in Brazil by Hatsuta Industrial S.A., Av. Monteiro Lobato, 2700 - CEP: 07190 - Guarulhos - SP - Brazil and imported.

From our study it does not fail under any federal regulations and since this is designed for off road use, we would like to get a confirmation from you that no other approvals are required.

If you should have any questions or comments or need additional information, please do not hesitate to contact me.

Attachment

WALK MACHINE (Graphics omitted) The Walk Machine is a new concept for pedestrian's mechanization. Safe and easy to drive, after few minutes of training, you will be ready to move economically along at speeds up to 16 MPH.

SUPER ECONOMIC

It is very economical - 37cc and 1 HP engine goes up to 50 miles with one liter of gas. Its 0,3 gallons fuel tank can take you for up to 62 miles. It is easier to handle than a bike, a motorcycle, or a car. Due to its extremely safe.

EASY TRANSPORT

The Walk Machine is light (40 pounds) and has a foldable handle - bar - you can transport in a car trunk - or on a car rack. You can take with you on a trip or on a day out without any problems!

SPECIFICATIONS

Engine......................... 2 strokes Cylinder capacity.............. 37 cc (2,25 cu. inches)

o Piston x Stroke.............. o 1,4 x 1,5 inches Maximum Power.................. 1 HP at 5.500 RPM Refrigeration.................. Air, "Ram - Air" flaps Ignition....................... Magnet and secondary coil Carburetor..................... Ventury piston type o 0,55 inches lubrification.................. 2 stroke oil 25:1 Traction....................... Pulleyes and belts Net Weight..................... 40 pounds Fuel Tank...................... 0.3 gallons Maximium Speed................. 16 miles p/ hr. Normal Speed................... 7,5 miles p/ hr. Maximium load.................. 220 pounds Tires.......................... 3.25 x 6 (special) Tire gauge..................... 18 to 20 lbs.

NOTE: The technical characteristics of this vehicle might be changed by the manufacturer without prior notice.

Walk Machine is a trade mark registered in USA and other countries Walk Machine is patented in USA and other countries.

WALK MACHINE CORPORATION HATSUTA INDUSTRIAL S.A. 17690 South Dixie Hwy (US - 1) Av. Monteiro Lobato, 2700 - CEP: 07190- Miami FL 33157, Florida USA Guarulhos - SP - Brazil Phone.: (305) 378-4564 / 378-4531 Tel.: (011) 209-2133 - Telex: 1165033 HABR - Fax.: (305) 378-9318 Fax: (011) 209-2593

ID: nht91-2.13

DATE: March 6, 1991

FROM: Kent Morris -- President, Memory Motors Inc

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-22-91 from Paul Jackson Rice to Kent Morris (A37; VSA 103(3); Sec. 571.7(e)

TEXT:

Per my phone conversation with Mr. Vinson today, I am writing to explain our product. I would like to know which, if any, NHTSA Guidelines our company should comply with.

Our company manufactures the M-53, a replica of the 19531955 Corvette. We sell the M-53 as a Kit and a Turnkey. We construct our body from fiberglass and do not use any used parts on it. The Kit is sold as a rolling unit. We use a used chassis from a 1978-1985 Chevrolet Monte Carlo. Because it is a unibody chassis, we cut the side frame rails out (which by the way, is the only place on the chassis that has a serial number). We then shorten the wheelbase 6", weld in an "X" frame member and new side rails. (See Drawings). The used rear axle assembly and front end components are also used. On our turnkey model we install a new engine from Chevrolet and we rebuild the automatic transmission.

Information we have received from the State of Texas says that if a vehicle is assembled using any used components (motor, frame, or body), then the person or firm assembling the vehicle is not a manufacturer. Is this correct and does it matter on a national basis?

Our production is very low, about one unit per month. Does production quantity have any bearing on compliance with federal safety laws or emissions?

I am enclosing our sales information to assist you in getting a clear picture of what we do. If you have any other questions please call. I hope you can respond soon. Thank you for your time.

Attachment

MEMORY MOTORS INC.

110 W. AVE. G CONROE, TEXAS 77301 (409)760-3500

M-53 CORVETTE REPLICA ROLLING CHASSIS

$9,500.00

* BODY IS MOUNTED ON CHASSIS AND IS SHIPPED AS A ROLLING UNIT. NO CRATING IS NECESSARY! * THE BODY IS ONE PIECE, HANDLAID FIBERGLASS. IT IS GEL-COATED IN A PRIMER COLOR AND NO BODY WORK IS NECESSARY! * FLOOR PAN, FIREWALL & DASH ARE LAMINATED INTO THE BODY * DOORS, HOOD, TRUNK, & CONVERTIBLE TOP LID ARE ALL FACTORY INSTALLED. THIS INCLUDES HINGES, LATCHES, STRIKERS & RELEASES * CORE MAT IS LAMINATED INTO VARIOUS BODY PANELS TO ADD STRENGTH & SOUND INSULATION * METAL PLATES ARE LAMINATED INTO THE BODY AT 20 DIFFERENT STRESS POINTS TO PROVIDE DURABILITY * BRACKETS ARE SUPPLIED FOR EMERGENCY BRAKE HANDLE, GAS PEDAL, BRAKE PEDAL, STEERING COLUMN & FRONT BUMPER * TRUNK & HOOD SUPPORT MECHANISMS * ALL NECESSARY WEATHERSTRIPPING * RADIATOR SUPPORTS * LATE MODEL GM CHASSIS READY FOR RECONDITIONING * WHEELBASE IS SHORTENED 6" * CUSTOM 2 X 4 "X-FRAME", MOTOR MOUNTS & BODY MOUNTS ARE WELDED INTO CHASSIS * REMOVABLE TRANSMISSION CROSSMEMBER BOLTS INTO "X" FRAME * 2"DROPPED SPINDLES ARE INCLUDED

DELUXE ROLLING CHASSIS

$10,800.00

* IN ADDITION TO THE ROLLING CHASSIS OUTLINED ABOVE, THE DELUXE CHASSIS HAS BEEN SANDBLASTED, PAINTED BLACK & RECONDITIONED WITH NEW PARTS INCLUDING: UPPER & LOWER BALL JOINTS, INNER & OUTER TIE ROD ENDS, TIE ROD SLEEVES, CENTER LINK, IDLER ARM, UPPER & LOWER A-FRAME BUSHINGS STABILIZER BAR LINK KITS & BUSHINGS, FRONT BRAKE PADS & CALIPERS, REAR BRAKE SHOES & WHEEL CYLINDERS, FRONT & REAR GREASE SEALS, BRAKE HOSES & SHOCKS * DIFFERENTIAL IS INSPECTED & SERVICED * DRUMS & ROTORS ARE RESURFACED * FRONT SPRINGS ARE MODIFIED & DROPPED SPINDLES ARE INSTALLED

PRICES EFFECTIVE DECEMBER 1, 1990

M-53 OPTIONS

COMPLETE 65 PIECE CHROME TRIM PACKAGE..................$3,900.00 1. AUTHENTIC TIGER TEETH, GRILL BAR & OVAL 2. BODY SIDE MOLDINGS INCLUDING GULL WINGS 3. FRONT & REAR BUMPERETTES 4. HEADLIGHT BEZELS & SCREENS 5. REAR LICENSE PLATE BEZEL & PLEXIGLASS LENSE 6. EXHAUST BEZELS 7. FRONT & REAR CENTER BUMPERS

8. DEFROSTER VENTS 9. W/S WASHER NOZZELS 10. DASH & DOOR MIRRORS 11. CONSOLE, SEAT SURROUND & TOP OF DOOR MOLDINGS

UPHOLSTERY PACKAGE.....................................$1,400.00

1. SEATS, DOOR & KICK PANELS, DASH & DOOR TRIM COME FULLY UPHOLSTERED 2. QUALITY LOOP CARPETING WITH JUTE PADDING, PRE-CUT TO FIT INTERIOR & TRUNK COMPARTMENTS & SOFT TOP SHELF 3. SEAT FRAMES WITH ADJUSTABLE SLIDES ON LEFT

INSTRUMENTATION PACKAGE................................$1,600.00

1. HEAD, TAIL, PARKING & LICENSE LIGHT ASSEMBLIES 2. CLOCK, TACHOMETER, FUEL LEVEL, OIL PRESSURE & TEMPERATURE GUAGES WITH SENDING UNITS 3. CUSTOM WIRING HARNESS COMPLETE WITH FUSE 4. ORIGINAL STYLE SPEEDOMETER

WINDSHIELD KIT...........................................$975.00

1. CHROME PLATED WINDSHIELD POSTS 2. CHROME PLATED EXTRUDED ALUMINUM UPPER & LOWER WINDSHIELD FRAMES 3. ORIGINAL REPLACEMENT SAFETY GLASS WINDSHIELD 4. RUBBER GASKETS

SOFT TOP PACKAGE.......................................$1,450.00

1. ORIGINAL STYLE FOLDING FRAME WITH BODY MOUNTS 2. ORIGINAL REPLACEMENT CANVAS WITH REAR WINDOW 3. CHROME FRONT LATCHES, REAR LATCHES & RECEIVERS 4. COMPLETELY ASSEMBLED

OTHER OPTIONS

1. HEATING & AIR CONDITIONING SYSTEM....................$795.00 2. CUSTOM BUILT FOUR ROW RADIATOR.......................$325.00 3. 15 GALLON ALUMINUM FUEL TANK.........................$295.00 4. WINDSHIELD WIPER SYSTEM (BLADES,ARMS,CHROME BEZELS, TRANSMISSIONS, LINKAGES, MOTOR W/MOUNTING BRACKET & SWITCH)....................................$330.00

PRICES EFFECTIVE DECEMBER 1, 1990 DONOR PARTS NECESSARY TO COMPLETE THE M-53

*CHEVROLET SMALL BLOCK W/ACCESSORIES *350 THM SHORT TAIL TRANSMISSION *DRIVESHAFT SHORTENED TO 33.5" CTC OF CAPS

*MOTOR & TRANSMISSION MOUNTS *STEERING COLUMN-FLOOR SHIFT, TILT STYLE W/SWITCHES *POWER BRAKE BOOSTER *BRAKE PEDAL ASSEMBLY *ACCELRATER PEDAL, CLIP & CABLE *HORNS *CHARCOAL CANNISTER *TRANSMISSION COOLER LINES, MODULATOR VACUUM LINE & KICKDDOWN CABLE *HEADLIGHT SWITCH ABOVE PARTS MAY BE OBTAINED FROM A 1976 AND UP "G" BODY INCLUDING; MONTE CARLO, GRAND PRIX, CUTLASS, REGAL, & MALIBU

*MASTERCYLINDER (FLAT TOP) *EMERGENCY BRAKE HANDLE ASSEMBLY AND CABLE GUIDE (1982 CHEVETTE) *HOOD RELEASE CABLE *SPEEDOMETER CABLE *FLOOR SHIFTER, FORD PN E6DZ721OF & E3DZ7218A.MODIFY PER MEMORY MOTORS *DUAL EXHAUST SYSTEM *FOUR ROW RADIATOR & HOSES *BATTERY, CABLES & TRAY *CUSTOM STEERING WHEEL *WHEELS & TIRES *FUEL FILLER NECK, HOSE & CAP *SPARE TIRE, JACK & LUG WRENCH

M-53

TURNKEY PRICING

$32,000.00 Base Price, Includes These Standard Features:

*Power Steering *Power Brakes: Front Disc/Rear Drum *New 350 Chevrolet Engine 4 BBL. *Rebuilt 350 Automatic Trasmission *Tilt Wheel *Dual Exhaust *All Around Coil Spring Suspension *Carpeting In Trunk, Soft Top & Passenger Compartments *Spare Tire, Jack And Lug Wrench *Wire Spoke Wheels *Wide White Wall Tires *12 Month/12,000 Mile Warranty

Options

$1,450.00 *Original Style Convertible Top $1,200.00 *A/C And Heater System $1,200.00 *Leather Interior $675.00 *Original Style Steering Wheel

$400.00 *Original Style Shifter $250.00 *Chrome Engine Dress Kit

Call For Information On Models In Stock *Allow 60-90 Days On Non-Stock Orders *Terms Are: 1/3 To Begin, 1/3 In 30-Days, Balance on Delivery.

M-53 CORVETTE REPLICA

ROLLING CHASSIS

$9,500.00

* BODY IS MOUNTED ON CHASSIS AND IS SHIPPED AS A ROLLING UNIT. NO CRATING IS NECESSARY! * THE BODY IS ONE PIECE, HANDLAID FIBERGLASS. IT IS GEL-COATED IN A PRIMER COLOR AND NO BODY WORK IS NECESSARY! * FLOOR PAN, FIREWALL & DASH ARE LAMINATED INTO THE BODY * DOORS, HOOD, TRUNK, & CONVERTIBLE TOP COVER ARE ALL FACTORY INSTALLED. THIS INCLUDES HINGES, LATCHES, STRIKERS & RELEASES * CORE MAT IS LAMINATED INTO VARIOUS BODY PANELS TO ADD STRENGTH & SOUND INSULATION * METAL PLATES ARE LAMINATED INTO THE BODY AT 20 DIFFERENT STRESS POINTS TO PROVIDE DURABILITY * FLOOR PAN, FIREWALL & DASH ARE LAMINATED INTO THE BODY * DOORS, HOOD, TRUNK, & CONVERTIBLE TOP COVER ARE ALL FACTORY INSTALLED. THIS INCLUDES HINGES, LATCHES, STRIKERS & RELEASES * BRACKETS ARE SUPPLIED FOR EMERGENCY BRAKE HANDLE, GAS PEDAL, BRAKE PEDAL, STEERING COLUMN & FRONT BUMPER * TRUNK & HOOD SUPPORT MECHANISMS * ALL NECESSARY WEATHERSTRIPPING * RADIATOR OR SUPPORTS * LATE MODEL GM CHASSIS READY FOR RECONDITIONING * WHEELBASE IS SHORTENED 6" * CUSTOM 2 X 4 "X-FRAME", MOTOR MOUNTS & BODY MOUNTS ARE WELDED INTO CHASSIS * REMOVABLE TRANSMISSION CROSSMEMBER BOLTS INTO "X" FRAME * 2" DROPPED SPINDLES ARE INCLUDED

DELUXE ROLLING CHASSIS

$10,800.00

* IN ADDITION TO THE ROLLING CHASSIS OUTLINED ABOVE,THE DELUXE CHASSIS HAS BEEN SANDBLASTED, PAINTED BLACK & RECONDITIONED WITH NEW PARTS INCLUDING: UPPER & LOWER BALL JOINTS, INNER & OUTER TIE ROD ENDS, TIE ROD SLEEVES, CENTER LINK, IDLER ARM, UPPER & LOWER A-FRAME BUSHINGS STABILIZER BAR LINK KITS & BUSHINGS, FRONT BRAKE PADS & CALIPERS, REAR BRAKE SHOES & WHEEL CYLINDERS, FRONT & REAR GREASE SEALS, BRAKE HOSES & SHOCKS * DIFFERENTIAL IS INSPECTED & SERVICED

* DRUMS & ROTORS ARE RESURFACED * FRONT SPRINGS ARE MODIFIED & DROPPED SPINDLES ARE INSTALLED

M-53 OPTIONS

COMPLETE 65 PIECE CHROME TRIM PACKAGE..................$3,900.00 1. AUTHENTIC TIGER TEETH, GRILL BAR & OVAL 2. BODY SIDE MOLDINGS INCLUDING GULL WINGS 3. FRONT & REAR BUMPERETTES 4. HEADLIGHT BEZELS & HEADLIGHT SCREENS 5. REAR LICENSE PLATE BEZEL & PLEXIGLASS COVER 6. EXHAUST BEZELS 7. FRONT & REAR CENTER BUMPERS 8. DEFROSTER VENTS 9. W/S WASHER NOZZELS 10. DASH & ODOR MIRRORS 11. CONSOLE, SEAT SURROUND & TOP OF DOOR MOLDINGS

UPHOLSTERY PACKAGE.....................................$1,400.00

1. SEATS, DOOR & KICK PANELS, DASH & DOOR TRIM COME FULLY UPHOLSTERED 2. QUALITY LOOP CARPETING WITH JUTE PADDING, PRE-CUT TO FIT INTERIOR & SOFT TOP SHELF 3. SEAT FRAMES WITH ADJUSTABLE SLIDES ON LEFT

INSTRUMENTATION PACKAGE................................$1,600.00

1. HEAD, TAIL. PARKING & LICENSE LIGHT ASSEMBLIES 2. CLOCK, TACHOMETER, FUEL LEVEL, OIL PRESSURE & TEMPERATURE GUAGES WITH SENDING UNITS 3. CUSTOM WIRING HARNESS COMPLETE WITH FUSE BLOCK, RELAYS & FLASHERS 4. ORIGINAL STYLE SPEEDOMETER

WINDSHIELD KIT...........................................$975.00

1. CHROME PLATED WINDSHIELD POSTS 2. CHROME PLATED EXTRUDED ALUMINUM UPPER & LOWER WINDSHIELD FRAMES 3. ORIGINAL REPLACEMENT SAFETY GLASS WINDSHIELD 4. RUBBER GASKETS

SOFT TOP PACKAGE........................................$1,450.00

1. ORIGINAL STYLE FOLDING FRAME WITH BODY MOUNTS 2. ORIGINAL REPLACEMENT CANVAS WITH REAR WINDOW 3. CHROME FRONT LATCHES, REAR LATCHES & RECEIVERS 4. COMPLETELY ASSEMBLED

OTHER OPTIONS

1. HEATING & AIR CONDITIONING SYSTEM......................$795.00 2. CUSTOM BUILT FOUR ROW RADIATOR.........................$325.00 3. 15 GALLON ALUMINUM FUEL TANK...........................$295.00

4. WINDSHIELD WIPER SYSTEM (BLADES, ARMS, CHROME BEZELS, TRANSMISSIONS. LINKAGES, MOTOR W/MOUNTING BRACKET & SWITCH)......................................$330.00

DONOR PARTS NECESSARY TO COMPLETE THE M-53

* CHEVROLET SMALL BLOCK W/ACCESSORIES * 350 THM SHORT TAIL TRANSMISSION * DRIVESHAFT SHORTENED TO 33.5" CTC OF CAPS * MOTOR & TRANSMISSION MOUNTS * STEERING COLUMN-FLOOR SHIFT, TILT STYLE W/SWITCHES * POWER BRAKE BOOSTER * BRAKE PEDAL ASSEMBLY * ACCELRATER PEDAL, CLIP & CABLE * HORNS * CHARCOAL CANNISTER * TRANSMISSION COOLER LINES, MODULATOR VACUUM LINE & KICKDOWN CABLE * HEADLIGHT SWITCH ABOVE PARTS MAY BE OBTAINED FROM A 1976 AND UP "G" BODY INCLUDING; MONTE CARLO, GRAND PRIX, CUTLASS, REGAL, & MALIBU

* MASTERCYLINDER (FLAT TOP) * EMERGENCY BRAKE HANDLE ASSEMBLY AND CABLE GUIDE (1982 CHEVETTE) * HOOD RELEASED CABLE * SPEEDOMETER CABLE * FLOOR SHIFTER, FORD PN E6DZ7210F & E3DZ7213A.MODIFY PER MEMORY MOTORS * DUAL EXHAUST SYSTEM * FOUR ROW RADIATOR & HOSES * BATTERY, CABLES & TRAY * CUSTOM STEERING WHEEL * WHEELS & TIRES * FUEL FILLER NECK, HOSE & CAPE * SPARE TIRE, JACK & LUG WRENCH

ID: nht91-2.14

DATE: March 6, 1991

FROM: Anthony J. Lalikos -- Project Engineer, Titeflex Corporation

TO: Vernon G. Bloom -- Crash Avoidance Division, DOT

TITLE: None

ATTACHMT: Attached to letter dated 5/12/94 from John Womack to Nicholas S. Copass (A42; Std. 106), letter dated 9/29/93 from Nicholas S. Copass to David Elias (OCC-9161), and letter dated 3/18/91 from Arthur H. Neill, Jr. to Anthony J. Lalikos

TEXT:

Enclosed, as per our phone conversation on March 6th, is the information needed to register TITEFLEX Corp. as an approved supplier of bulk brake hose and brake hose assemblies.

TITEFLEX CORPORATION shall be identified by the following marking on its products:

(GRAPHICS OMITTED) (The TITEFLEX Logo)

All Products are manufactured by:

TITEFLEX CORPORATION 603 Hendee Street Springfield, Massachusetts 01109

Phone - (413) 739-5631

Please refer any questions or comments to Doug Colby or Tony Lalikos, and please call us when our registration is confirmed. Thank you.

ID: nht91-2.15

ID: nht91-2.16

DATE: March 7, 1991

FROM: Paul Jackson Rice -- Chief Counsel

TO: Sidney A. Garrett -- President, Brown Cargo Van, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 4-25-90 from Stephen P. Wood to J. Douglas Smith (Std. 108); Also attached to letter dated 2-15-91 from Sidney A. Garret to U.S. Department of Transportation, NHTSA (OCC 5732)

TEXT:

This is in reply to your letter of February 15, 1991, asking the agency for an interpretation of Motor Vehicle Safety Standard No. 108 as it pertains to the location of front clearance and identification lamps on truck van bodies.

Specifically, where the chassis-cab is equipped with clearance and identification lamps, you have asked whether this relieves you, as the manufacturer of the van body, from installing additional clearance and identification lamps on the van body. If the answer is no, you have asked whether the van body may be equipped with clearance lamps only, or must it be equipped with both clearance and identification lamps.

We answered a similar request on April 25, 1990, and I enclose a copy of our response for your guidance. With respect to your particular design, the clearance lamps mounted on the cab would not be as near the top of the completed motor vehicle as practicable, and therefore must be located on the van body. However, identification lamps may be mounted on the cab, and your lamps located as shown in your Exhibit 2 would meet Standard No. 108. Identification lamps may also be mounted on the van body, and Exhibit 3 would also meet the location requirements of Standard No. 108.

ID: nht91-2.17

DATE: March 7, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Terry Rowe -- President, Show Trucks U.S.A., Inc.

TITLE: None

ATTACHMT: Attached to letter dated 6-11-90 from Terry Rowe to Office of the Chief Council (OCC 4889)

TEXT:

This responds to your letter asking whether your company would be considered a vehicle "alterer," within the meaning of 49 CFR Part 567 certification, and Part 568 Vehicles Manufactured in Two or More Stages. I apologize for the delay in this response. Based on the statements in your letter that your company modifies only new vehicles before delivery to customers and that the modifications performed by your company do not affect the vehicles' gross axle or gross vehicle weight ratings, your company would be considered an "alterer, and would be subject to additional certification requirements, if the modifications involve something more than the addition, substitution, or removal of "readily attachable" components. A more complete explanation of your responsibilities under NHTSA's laws and regulations follows.

S567.7 imposes additional certification requirements on "a person who alters a vehicle that has previously been certified in accordance with S567.4 or S567.5, other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, ..." You stated in your letter that your company can provide features such as a 3-piece seating system, removable headrest, custom walnut steering wheel, and tinted windows. Your company is an "alterer" subject to the requirements of S567.7 to the extent that your modifications do not involve "readily attachable" components.

A determination of whether modifications involve readily attachable, components depends on the degree of difficulty in attaching these components. To ascertain whether the installation involves readily attachable" components, the agency in the past has looked at such factors as the intricacy of installation and the need for special expertise must be taken into consideration. Absent extraordinary ease of installation, NHTSA would not consider modifications involving the addition or substitution of seats, headrests, and steering wheels to involve readily attachable" components. To the extent your company is involved in such modifications, then, it would have to affix an additional certification label pursuant to S567.7. Further, an alterer is considered a "manufacturer" for the purposes of notification and remedy for defects or noncompliances with the safety standards, and is subject to the requirements of 49 CFR Part 573, Defect and Noncompliance Reports.

You should also note that the National Traffic and Motor Vehicle Safety Act sets forth certain prohibitions and requirements that would apply to these vehicle modifications, even if the modifications involved only "readily attachable" components. For example, section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits the sale, offer for sale,

introduction into interstate commerce or importation of any vehicle that does not comply with all applicable Federal motor vehicle safety standards. This provision of Federal law means that all of the vehicles modified by your company must continue to comply with all applicable safety standards after the modifications have been made. In addition, under section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)), no manufacturer, distributor, dealer, or motor vehicle repair business may knowingly render inoperative, in whole or in 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.

For your information, I have enclosed an information sheet which identifies relevant Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers, and explains how to obtain copies of those regulations. Again I apologize for the delay in this response. If you have any further questions or need any additional information, please feel free to contact Dorothy Nakama of may staff at this address or by telephone at (202) 366-2992.

Attachment

Information sheet from NHTSA dated September, 1985 titled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment. (Text omitted)