ID: nht75-6.39

DATE: 05/09/75

FROM: James B. Gregory -- Administrator, NHTSA

TO: J. C. Carruth -- President, Canadian Trucking Association

TITLE: NONE

TEXT: The Secretary has asked me to respond to your letter of March 17 (F-50-A) requesting relief from a provision of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1391 et seq.) that prevents operation in the United States of Canadian vehicles which were not manufactured in conformity with Standard No. 121, Air brake systems. You request a temporary exclusion from the standard for Canadian-based commercial vehicles operating in the United States, whether or not they are manufactured in Canada.

The National Traffic and Motor Vehicle Safety Act provides that no person shall import into the United States a motor vehicle manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect unless it is in conformity with the standard (@ 1397(a)(1)(A)). Sections 1397(b)(3) and (b)(4) specifically address importation:

@ 1397

(3) A motor vehicle or item of motor vehicle equipment offered for importation in violation of paragraph (1)(A) of subsection (a) of this section shall be refused admission into the United States under joint regulations issued by the Secretary of the Treasury and the Secretary.

(4) The Secretary of the Treasury and the Secretary may, by joint regulations, permit the temporary importation of any motor vehicle or item of motor vehicle equipment after the first purchase of it in good faith for purposes other than resale.

The only exception to these laws is promulgated in Part 12 of the customs regulations (19 CFR @ 12.80). One exception permits temporary importation for personal use, but it does not apply to commercial use of U. S. highways.

Section 1392(g) of the Act also mandates that the Bureau of Motor Carrier Safety (referred to in the section as the Interstate Commerce Commission) "not adopt or continue in effect any safety standard which differs from" our standards unless it is a higher standard of safety. The Bureau has indicated its intent to adopt Standard No. 121 as its performance standard in the regulation of U. S. and foreign motor carriers on U. S. highways.

I conclude that any exclusion of Canadian vehicles from Standard No. 121 would be an evasion of the Act's prohibition on importation of noncomplying vehicles. Such an exclusion would reduce the expected benefits of Standard No. 121 and would discriminate against U. S. manufacturers and carriers. For those reasons, your request is denied.

For clarification, I note that the standard applies (with limited exceptions) to air-braked trailers manufactured after January 1, 1975, and air-braked trucks and buses manufactured after March 1, 1975. I am unaware of the significance of the March 31, 1975, date to which you refer.

ID: nht75-6.4

DATE: 03/31/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Oshkosh Truck Corporation

TEXT: This is in reply to your letter of February 25, 1975, requesting our review of certain sections of the "Part 568" document Oshkosh wishes to use for all its vehicles.

We believe you may use a rubber stamp which states, "Standard No. 121 Not Applicable" over the part of the document regarding conformity with Standard No. 121, for vehicles to which the standard does not apply. We would, however, add the words, "to this vehicle."

Your statement in the document regarding Standard No. 116 also conforms to the requirements of Part 568.

Finally, you are correct with respect to the language of @ 568.4(a)(7). The reference to "(7)" in that section should be "(6)."

ID: nht75-6.40

DATE: APRIL 16, 1975

FROM: MR. SICKS; MR. PETZOLDT -- FACHNORMENAUSSCHUSS

TO: NHTSA, DOCKET SECTION

TITLE: BURNING BEHAVIOUR OF INTERIOR MATERIALS FOR MOTOR VEHICLES

ATTACHMT: ATTACHED TO LETTER DATED 5-9-75 TO MR. SICKS FROM RICHARD B. DYSON

TEXT: In March 1975 the ISO Central Secretariat has published DRAFT INTERNATIONAL STANDARD

ISO/DIS 3795 - Road vehicles - Determination of burning behaviour of interior materials for motor vehicles

Please find enclosed the English version of this Draft International Standard. As mentioned in our letter of September 3, 1974 Sub-Committee 16 decided to require in this Draft International Standard the presence of supporting wires in all cases in order to avoid subjective interpretations of sample behaviour by the test personnel. As it is essential that laboratories charged with flammability tests conduct these tests according to the same procedure, we ask you to take into consideration the specifications of ISO/DIS 3795. We would appreciate it very much, if you could modify MVSS 302 so that also this standard requires the presence of supporting wires in all tests. We look forward to receiving your reply.

(Attachment Omitted)

ID: nht75-6.41

DATE: MAY 09, 1975

FROM: RICHARD B. DYSON -- ASSISTANT CHIEF COUNSEL, NHTSA

TO: MR. SICKS -- FACHNORMENAUSSCHUSS KRAFTFAHRZEUGE - FAKRA

COPYEE: F. W. SCHWARTZ

TITLE: NONE

ATTACHMT: LETTER DATED 4-16-75 TO NHTSA DOCKET SECTION FROM MR. PETZOLDT AND MR. SICKS, FACHNORMENAUSSCHUSS KRAFTFAHRZEUGE

TEXT: This is in response to your Petition for Reconsideration of the amendments to Federal Motor Vehicle Safety Standard No. 302 promulgated in the Federal Register on March 31, 1975.

We shall advise you of our decision in this matter after reviewing your petition.

ID: nht75-6.42

DATE: 09/24/75

FROM: J. C. ECKHOLD -- DIR., AUTOMOTIVE SAFETY OFFICE, FORD MOTOR CO.

TO: JAMES B. GREGORY -- ADMINISTRATOR, NHTSA

TITLE: REQUEST FOR INTERPRETATION IN RELATION TO CONDUCTING FMVSS 301-75 TESTS WITH PROPOSED 1978 EVAPORATIVE EMISSION SYSTEM

TEXT: In preparing for compliance with 1978 California SHED evaporative emission requirements (presently under consideration by EPA for application in all areas), Ford Motor Company (Ford) is considering modifications to the fuel tank vapor venting system. At this time, Ford's primary design direction for certain of its 1978 vehicles is to incorporate a pressure relief valve in the vapor vent tube between the fuel tank vapor separator/rollover valve and the carbon canister (see Attachment).

When the engine is operating, this pressure relief valve will be open and the fuel tank will vent in a normal manner through the carbon canister. When testing according to the procedure set forth in FMVSS 301-75, the pressure relief valve would be closed, contrary to its normal open position when the engine is operating, and such closure would prevent venting of vapor from the fuel tank into the carbon canister. As a result, vapor pressure could build up within the fuel tank during FMVSS 301-75 testing, and indeed would do so if the fuel tank were exposed to elevated ambient temperatures during the substantial time period (in some instances several hours) required to ready the test vehicle for the rollover test following an impact test. If such pressure built up, it (taken together with the hydrostatic pressure of the Stoddard solvent in the tank) might force open the vacuum/pressure valve in the fuel tank cap and permit leakage through that valve (cap).

Such leakage would not occur in an accident involving a rollover because, in such a situation, vapor pressure would not build up in the fuel tank, and therefore, the vacuum/pressure valve in the cap would not open. Any rollover of the vehicle that may occur would happen immediately after the collision, before vapor pressure build-up. Hence the vacuum/pressure valve (cap) would remain closed after rollover. More particularly, just before the accident, the vapor vent tube pressure relief valve would be open, preventing vapor pressure build-up.

Accordingly, Ford proposes to perform tests relating to compliance with FMVSS 301-75 with the vapor vent tube pressure relief valve open, the better to simulate actual usage conditions. Before testing in this manner, Ford would appreciate receiving assurance from the Administration that it regards as appropriate the maintaining open of this pressure relief valve during rollover tests, and would conduct in that manner its rollover tests of those Ford vehicles equipped with such a valve.

As you are undoubtedly aware, in addition to design and development work, a test program required to obtain emission certification covers a period of many months. Therefore, since Ford has only a limited time in which to develop a 1978 evaporative emission system complying with the SHED requirements, an early response to this letter is urgently requested.

ATTACHMENT

PROPOSED 1978 EVAPORATIVE EMISSION SYSTEM

(Graphics Omitted)

ID: nht75-6.43

DATE: 10/17/75

FROM: JOHN B. WHITE -- ENGINEERING MANAGER, TECHNICAL INFORMATION DEPT., MICHELIN TIRE CORPORATION

TO: MR. SCHWIMMER -- OFFICE OF THE CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11-10-75 TO JOHN B. WHITE FROM FRANK A. BERNDT.

TEXT: This is in regard to our telephone conversation of yesterday concerning truck tires brought into the U.S.A. to be mounted on vehicles which are to be exported outside the U.S.A.

Please verify that tires imported for this purpose need not conform to FMVSS 119, Pneumatic Tires for Vehicles other than Passenger Cars or Part 574, Tire Identification and Record Keeping.

This decision affects a current tire shipment, so therefore we would appreciate your prompt reply.

Thank you.

ID: nht75-6.5

DATE: 04/25/75

FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA

TO: New York Department of Transportation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 7, 1975, asking whether, consistently with Federal law, the New York Commissioner of Transportation may waive a safety rule which is based on a Federal safety regulation. You indicate that New York has rules which permit waivers of New York requirements. The case in point involves a waiver given to a bus owner who, because his vehicle was to be used only in the transportation of nursery school children, requested that the allowable occupant weight be set at 100 pounds rather than 120 pounds. The waiver was provided by giving the owner-operator of the vehicle a valid certificate of inspection.

The facts of the case, particularly how the vehicle in question is equipped and labeled, are not altogether clear from what you have told us. It appears that the manufacturer of the bus has labeled it with a gross vehicle weight rating that, contrary to the Federal certification regulations (49 CFR Part 567(g)(3)), does not equal the unloaded vehicle weight plus 120 pounds times the number of designated seating positions in the bus.

It appears from your correspondence that the certificate of inspection issued by the New York authorities fulfills purposes that differ from those of the Federal certification regulations. There is no Federal requirement that the State inspection rules incorporate the Federal requirements, as long as they do not conflict with the Federal safety standards or associated regulations. However, if the manufacturer has violated the Federal law, he is subject to its sanctions, and nothing the State can do would "forgive" the violation. If our assumptions concerning the facts of the case are correct, the State is free to deal as it sees fit with the fact that the bus does not conform to the Federal regulations.

Sincerely,

NEW YORK STATE DEPARTMENT OF TRANSPORTATION

February 7, 1975

Karen Kreshover, Esq. National Highway Traffic Safety Administration Department of Transportation

Re: pre-emption of state safety standards for buses: Request for interpretation

This is a formal request for an interpretation of the preemptive status of certion federal rules concerning bus safety. I spoke with you briefly on the phone on February 6, 1975 about this problem.

New York has rules (17 NYCRR 720.26 and 721.33) which permit the Commissioner of Transportation under certain conditions to, in effect, waive certain safety rules. I attach copies of these "waiver" provisions.

My question generally is, can the Commissioner "waive" or grant exception to rules adopted by New York which are based on federal requirements.

The particular application of this question concerns the definition stated in the National Highway Traffic Safety Administration rules concerning the definition of "Gross Vehicle Weight Rating." The rule (49 CFR 567.4) uses a 120 pound per pupil factor in determining GVWR. New York has a similar standard (17 NYCRR 720.1 (e) and 721.1 (p).

In at least one instance the Commissioner of Transportation has granted an exception concerning this rule. I am enclosing a copy of the order and report concerning this proceeding. This represents one example where a rule adopted to apply to the "average case" works hardship on a "special case." We believe that the Commissioner of Transportation of the State of New York should be free to grant exceptions in such cases.

I thank you in advance for your cooperation.

Michael D. McDonald Assistant Counsel

Historical Note

See added (Illegible Words) (Illegible Numbers)

720.26 Exception to safety regulations. (a) The commissioner upon application, may adopt an order issuing a certificate of inspection to the current owner or operator of a motor vehicle subject to this Part which falls to meet or achieve certain standards or requirements contained within this Part, if the commissioner shall determine that said vehicle as designed, constructed, altered or modified is safe to be operated within this State, and that the specific deviations from the standards and requirements contained in this Part in no way render such vehicle lens safe to passengers or to the public than had the vehicle complied with such provisions. Any order adopted pursuant to this section shall set forth the specific provisions contained in this Part with which the vehicle fails to comply, and in addition, state the reasons why the commissioner has so determined that the vehicle should be granted a certificate of inspection.

(b) The commissioner, or his duly authorized representative shall endorse clearly and legibly on the face of the certificate of inspection issued pursuant to this section that said certificate was issued pursuant to this section.

Historical Note

Sec. added, filed Mar. 29, 1974 off. Apr. 1. 1974

721.33 Exception to safety regulations. (a) The commissioner, upon application, may adopt an order issuing a certificate of inspection to the current owner or operator of a bus subject to this Part which fails to meet or achieve certain standards or requirements contained within this Part, if the commissioner shall determine that said vehicle as designed constructed, altered or modified is safe to be operated within this state, and that the specific deviations from the standards and requirements contained in this Part in no way render such vehicle less safe to passenger or to the public than had the vehicle complied with such provisions. Any order adopted pursuant to this section shall set forth the specific provisions

CHAPTER VI TRANSPORTATION REGULATION

@ 722.2 (Illegible Lines)

PART 722

REPORTS OF ACCIDENTS

(Statutory authority: Transportation Law @ 142)

See

721.0 Applicability

722.1 Reportable accidents

See

722.2 Accident report forms

722.3 (Illegible Word) to his reports

Historical Note

Part (@@ 722.0-722.2) filed Mar. 29, 1974 eff. Apr. 1, 1974.

Section 722.0 Applicability. Every operator of a motor vehicle subject to Department of Transportation inspection is hereby directed and required to comply with and obey the following rules and regulations.

Historical Note

See added, filed Mar. 29, 1974 eff. Apr. 1, 1974.

722.1 Reportable accidents. (a) Any accident in any way involving a motor vehicle subject to department inspection which results in the loss of life or injury of any passenger, employee or other person, or which was caused by mechanical failure regardless of whether or not injuries were incurred, shall be immediately reported to the department of telephone or telegraph.

(b) No work shall be performed on the vehicle involved until it is released by the Department of Transportation.

Historical Note

See, added filed Mar. 29, 1974 eff. Apr. 1, 1974.

722.2 Accident report forms. (a) An accident in any way involving a motor vehicle subject to department inspection which results in the loss of life or serious injury, or an injury requiring first aid or hospitalization at the time of the accident, shall be reported in writing to the department within 48 hours after it occurs. A written report shall be submitted within 48 hours when an accident was due to mechanical failure, regardless of whether or not personal injury occurred.

(b) Such written report may be submitted on an 8 1/2 inch by 11 inch sheet of paper duplicating such Form A. Appendix B-2, infra. In lieu thereof, such report may be submitted on a Federal Department of Transportation accident report form or on the accident report form required by the New York State Commissioner of Motor Vehicles.

2475 TR 3-31-74

NEW YORK STATE DEPARTMENT OF TRANSPORTATION

At the Office of the Department of Transportation in the City of Albany December 23, 1974

PRESENT:

Martin D. Zell, Assistant Commissioner for Transportation Regulatory Affairs

CASE 27647 - In the Matter of the issuance of a certificate of inspection to the current owner or operator of a bus or other motor vehicle pursuant to Section 720.26 or 721.33 of Title 17 of the Official Compilation of Codes, Rules and Regulations of the State of New York. APPLICATION OF ABC CHILD CARE, INC. FOR EXCEPTION TO SECTION 720.1 (1).

ABC Child Care, Inc., having requested a certificate of inspection pursuant to the requirements and provisions of Section 720.26 of Title 17 of the Official Compilation of Codes, Rules and Regulations of the State of New York, said certificate to be affixed to certain vehicles owned and operated by the carrier, and said vehicles having been presented for inspection and the Commissioner having determined that the vehicles deviate from certain standards set forth in his safety rules and regulations, and the Commissioner having further determined that such vehicles are safe to be operated within this State under certain conditions, and further, that the specific deviations from his safety rules and regulations in no way renders said vehicles less safe to passengers or to the public than had the vehicles complied with such provisions, it is

ORDERED:

1. To the extent and under the conditions set forth in the attached memorandum, ABC Child Care, Inc. is relieved from compliance with the requirements contained in Section 720.1 (1) of Title 17 of the Official Compilation of Codes, Rules and Regulations of the State of New York, insofar as said regulations pertain to the use of certain vehicles owned and operated by the said carrier.

2. That if said vehicles otherwise complied with all of the applicable safety rules and regulations, a certificate of inspection shall be issued and affixed to said vehicles and there shall be endorsed clearly and legibly on the face of the certificate of inspection so issued a notation indicating that the certificate was issued pursuant to Section 720.26 of the above entitled regulations.

3. That this order and the certificate of inspection issued herein, shall remain in effect only for such period as said vehicles shall be used in the manner, under the conditions, and for the purpose set forth in the attached memorandum, and unless the Commissioner shall otherwise order.

4. That this order shall become effective immediately.

By the Assistant Commissioner for Transportation Regulatory Affairs

THOMAS B. TYREE Department Secretary

MEMORANDUM

APPROVED DEC 23 1974

DEPARTMENT OF TRANSPORTATION

DATE December 12, 1974

SUBJECT CASE 27647 - In the matter of the issuance of a certificate of inspection to the current owner or operator of a bus or other motor vehicle pursuant to Section 720.26 or 721.33 of Title 17 of the Official Compilation of Codes, Rules and Regulations of the State of New York.

APPLICATION OF ABC CHILD CARE, INC. FOR EXCEPTION TO SECTION 720.1 (1).

FROM M. V. Chauvin, Traffic and Safety Division, Room 720, Bldg. 7A

TO M. D. Zell, Off. of Transp. Regulatory Aff., Room 503, Bldg. 5

ABC Child Care, Inc., Woodside, New York, has requested exception to Section 720.1 (1) of rules governing the safety of motor carriers of passengers which sets passenger weight of a school child at 120 pounds.

Mr. Tom Fasciolo, director of the school, has made this request on the basis of the limited clientele (youngsters age 3 to 6) that this nursery school serves. Considering that children in the 3 to 6 age bracket will not meet or exceed a weight of 100 pounds, it seems reasonable to reduce the requirement to meet the individual situation. In discussing this with Mr. Fasciolo it was learned that these vehicles are used exclusively to transport the nursery school children when operated in service that comes under the New York State Department of Transportation jurisdiction.

Therefore, it is recommended that an order be adopted granting permission to the ABC Child Care, Inc., 66-26 Laurel Hill Blvd., Woodside, New York to use a passenger weight of 100 pounds per nursery school child, with the understanding that the vehicles will be limited to the transportation of nursery school children exclusively.

ID: nht75-6.6

DATE: 07/08/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Athens Sport Cycles Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of May 18, 1975, in which you ask a number of questions relating to tire registration procedures, and in amplification of your telephone conversation with Mr. Schwartz of my office. We will answer your questions in the order raised.

1 and 2. There is a universal tire registration form (figure 3 in the enclosed Part 574) which manufacturers are required to furnish to you or you may reproduce pursuant to @ 574.7 of the regulation.

3. Since the regulation requires that the manufacturers or their agents maintain the records, the forms should either be sent to the manufacturer or his designated agent. A number of manufacturers utilize services such as the Tire Safety Registry in New Jersey to keep their records, but they merely act as the manufacturer's agent. There is to our knowledge no central place to send the forms for all manufacturers.

4. We have no idea what is meant by a retailer I.D. number. Our recommendation is that you contact the manufacturers to determine what they mean.

5. Our tire recordkeeping regulation only applies to tires for use on motor vehicles. Thus, tires for use on off-road vehicles would not fall within the regulation.

6. As required by @ 574.8 of the enclosed regulation, completed forms must be sent to manufacturers every 30 days. The only exception is where you sell less than 40 tires of all makes and manufacturers in the 30-day period, in which case you may wait until you sell 40 tires or for 6 months, whichever comes first.

7. Retailers are not required to keep any tire owner forms.

8. It is the responsibility of the dealer to mail the forms, although he may ask the customer to fill out the form at the time of purchase.

On behalf of the National Highway Traffic Safety Administration, let me commend you for your desire to fully comply with the requirements of our tire recordkeeping regulations. It is through the efforts of dealers such as you that motorcyclists and their passengers are protected against tire defects which might lead to injury or death.

ID: nht75-6.7

DATE: 06/10/75

FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA

TO: Franklin Coach Company Inc.

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for submitting your draft defect notification letter for our review. We find that the draft fails in several respects to conform to regulations specifying the content of the notification (49 CFR Part 577, Defect Notification, copy enclosed). First the reference in the second sentence of your letter to "your motor home" does not contain the identifying criteria required by section 577.4(b)(1). The sentence should more objectively identify the motor home, preferably by model number and name.

It appears from the facts you present that in addition to adding new leaf springs, the certification label on the vehicles should be replaced. An upgrading of the vehicle's carrying capacity should be reflected in both its gross vehicle and axle weight ratings. A correct certification label should reflect the values as they apply to the repaired vehicle. Your notification letter should therefore specify steps the owner can take to correct the certification label (@ 577.4(e)). One method you should consider is to furnish to each owner a corrected certification label with instructions for its installation by him.

Your letter also fails to conform to section 577.4(e)(3), which applies when the manufacturer does not offer to assume the cost of the repair. It appears from your description that you are modifying the existing springs, and they should be identified by name and part number (@ 577.4(e)(3)(ii)). You also have not provided a required detailed description (including appropriate illustrations) of each step required to repair the defect (@ 577.4(e)(3)(iv).

Finally, the requirements of section 577.4(e)(3)(iii) require the manufacturer to take positive steps to determine the availability of repair parts. You are obligated to at least determine whether the parts you recommend for replacement are in fact available. We do not believe you have met this requirement by merely stating that the parts "should be available." You can probably obtain this information by contacting the vehicle manufacturer, or by finding comparable repair parts in the replacement market.

YOURS TRULY,

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Act. Franklin Coach Company, Inc. has determined that a defect which relates to motor vehicle safety exists in your motor home.

The defect is in the weight of your vehicle; when the designated number of seating capacity is multiplied times 150 pounds and added to the unloaded vehicle weight of your motor home, it is 200 pounds over weight.

The malfunction that may occur is difficulty in controlling the vehicle when operating on curves and rough roads. To reduce the chance that the malfunction will occur before the vehicle is repaired, the purchaser should reduce the water carried and the gasoline carried by 1/2 - this will reduce the vehicle weight by approximately 200 pounds.

The risk of safety to the vehicle will increase with the age of the vehicle. Vehicle crash can occur. However, preceeding crash there will be a noticeable difficulty in controlling the vehicle. When difficulty in controlling unit occurs, the vehicle must be lightened in weight.

The parts that must be installed is the addition of one leaf to the springs on each side of the motor home on the rear axle. The part number is: #3638194 at a list price of $25.80 each. The parts should be available at any Dodge dealer. The estimated time of installation is 3 hours. We recommend that the necessary work be performed by your local Dodge dealer.

FRANKLIN COACH COMPANY, INC.

Steve Abel Controller

ID: nht75-6.8

DATE: 10/31/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Dunlop Tire and Rubber Corporation

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of July 8, 1975, to Ed Wallace of our Tire Division, enclosing a letter from Mr. W. Preuss of Dunlop Germany, concerning the allocation, between vehicle manufacturers and tire manufacturers, of responsibility for the safety of original equipment tires.

Section 159 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended by the Motor Vehicle and Schoolbus Safety Amendments of 1974, specifies that, except as otherwise provided in regulations of this agency, a defect in or noncompliance of an original equipment tire shall be the responsibility of the vehicle manufacturer. The NHTSA has recently granted the petitions of the Motor Vehicle Manufacturers Association, General Motors, and the European Tyre and Rim Technical Organisation for a reallocation of this responsibility. We expect to issue a notice of proposed rulemaking on this subject in the near future.

YOURS TRULY,

July 8, 1975

E. N. Wallace Chief, Tire Division National Highway Traffic Safety Administration

Further in regard to our letter of July 1st, which had enclosures from Bob Clifton, I am attaching a copy of a letter from Mr. Preuss of Dunlop Germany to Mr. Clifton, concerning Part 577, Notice 1, May 6, 1975.

Will you please discuss in your circle and let me have your comments.

DUNLOP TIRE & RUBBER CORPORATION

J. W. Boyd, Manager

Government & Industry Technical Relations