ID: aiam3507

Dear Mr. Yokoi: The answers to the questions in your letter of January 20, 1982, ar 'yes' to both questions.; >>>1. The 'adjacent layers' referenced in Federal Motor Vehicle Safet Standard (FMVSS) No. 106, paragraph S7.3.7, are (a) the inner tube and braided layer and (b) the braided layer and outer tube.<<<; >>>2. The adhesion requirements are met if both the tensile strength measured between (a) the inner tube and braided layer and (b) that between the braided layer and the outer cover are equal to or greater than 8lbs/inch as determined using the FMVSS No. 106 procedure. It should be noted that the 8lbs/inch value is an absolute minimum value as indicated in paragraph S8.6.4(a) of the standard.<<<; A copy of FMVSS No. 106 is included for your information. Sincerely, Vernon G. Bloom, Safety Standards Engineer

ID: aiam3733

Dear Mr. Nakaya: This is in response to your letter of July 8, 1983 asking for a interpretation of Motor Vehicle Safety Standard No. 108.; Section S4.2 of SAE Standard J588e *Turn Signal Lamps* establishes minimum distance of 4 inches from the optical axis (filament center) of the front turn signal to the inside diameter of the retaining ring of the headlamp providing the lower beam. You believe that it is not necessary to have a retaining ring on a semi-sealed headlamp and you have asked whether you may substitute the edge of the reflector (as shown on your drawing) to measure the dimension covered by S4.2 of J588e.; The point depicted on your drawing appears to be the inner edge of th reflector, rather than the extreme edge, nevertheless, the 'reflector edge' you have indicated is the approximate location of a retaining ring on a fully sealed headlamp, and is therefore acceptable as a measuring point under Standard No. 108.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam3678

Dear Mr. Brown: This is in response to your March 28, 1983, letter to Roger Fairchil of this office, requesting confirmation of your understanding of the effective dates for the recent suspension of treadwear grading under this agency's Uniform Tire Quality Grading Standards.; Your understanding of the effective dates is correct. Tires produced i molds manufactured on or after August 8, 1983, must have the new grading format which excludes treadwear information. Tires produced in molds manufactured before that date may either use the new format as soon as feasible, to minimize the dissemination of misleading information with regard to tire treadwear.; With regard to labels, the requirement that such labels must contai information regarding treadwear grades was suspended effective February 7, 1983. The preamble to the final rule states that manufacturers will be permitted to exhaust inventories of labels which were in existence as of the date of the suspension. Thereafter, manufacturers should begin using labels without treadwear information.; If you have further questions on this matter, please feel free t contact us.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam3547

Dear Mr. Blair: This is in reply to your letter of March 5, 1982, asking whether proposed motorcycle taillamp assembly would comply with Motor Vehicle Safety Standard No. 108.; As you point out, the standard requires a minimum distance of 4 inche edge to edge between turn signal lamps and stop/tail lamps. Since you state that you cannot achieve this with your design, the lamp as currently designed would not be permitted by our standard. This will confirm the oral interpretation provided by Taylor Vinson of this office when you telephoned on March 22.; You will be interested to know that we are presently studying side an rear conspicuity of motorcycles. This research is being conducted by Ketron in Philadelphia, Pennsylvania, and the final report is expected in July 1982 should you wish to obtain a copy of it from us.; As you requested confidential treatment of your engineering drawing, w are returning it to you.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam2399

Dear Mr. Crampton: This is in response to your letter of August 24, 1976, in which you as whether emergency exits required by a State beyond those required by Standard No. 217, *Bus Window Retention and Release*, are subject to the performance requirements outlined in S4(b) of Standard No. 220, *School Bus Rollover Protection*.; Standard No. 220 requires that all emergency exits provided i accordance with Standard No. 217 must meet certain minimum performance levels during and after the simulated rollover test. Additional emergency exits mandated by State law are not exits 'provided in accordance with Standard No. 217' and, therefore, would not be subject to the requirements of S4(b) of Standard No. 220.; You should note that Standard No. 217, in addition to mandating th provision of certain school bus doors and exits under S5.2, also regulates certain aspects of all emergency exits under other provisions of the regulation.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam2398

Dear Mr. Crampton: This is in response to your letter of August 24, 1976, in which you as whether emergency exits required by a State beyond those required by Standard No. 217, *Bus Window Retention and Release*, are subject to the performance requirements outlined in S4(b) of Standard No. 220, *School Bus Rollover Protection*.; Standard No. 220 requires that all emergency exits provided i accordance with Standard No. 217 must meet certain minimum performance levels during and after the simulated rollover test. Additional emergency exits mandated by State law are not exits provided in accordance with Standard No. 217' and, therefore, would not be subject to the requirements os S4(b) of Standard No. 220.; You should note that Standard No. 217, in addition to mandating th provision of certain school bus doors and exits under S5.2, also regulates certain aspects of all emergency exits under other provisions of the regulation.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: nht80-3.44

DATE: 08/29/80

FROM: FRANK BERNDT -- CHIEF COUNSEL, NHTSA; SIGNATURE BY STEPHEN P. WOOD

TO: Aston Martin Lagonda (1975) Limited

TITLE: FMVSS INTERPRETATION

TEXT: I have in hand your letter of July 31, 1980, and regret to inform you that the vehicle identification number (VIN) scheme which you propose is apparently not in compliance with U.S. Federal Motor Vehicle Safety Standard No. 115.

S4.5.2 and Table 1 of Standard No. 115 provide that the following information shall be decipherable from the five characters comprising the second section of the VIN for passenger cars: Line, Series, Body Type, Engine Type, Restraint System Type. A review of your Engineering Instructions and the accompanying drawings do not provide information concerning either the engine type or the restraint system type. Likewise, it is not clear whether your model designation is more appropriately characterized as line and/or series.

If the information omitted remains constant throughout a particular model, it will only be necessary for you to so state when deciphering your model code. For example, the following would be permissible:

Position 5 and 6: "V8" means V8 Volante model LHD, seat belt manual restraint system, V-8 engine with a displacement of 5.3 liters/326 cubic inches, a compression ratio of 8.3 and a net brake horsepower of .

We would also call to your attention that gross vehicle weight class is not required to be encoded in the VIN, although you are free to do so if you so choose.

Amongst the material furnished to the agency were drawings indicating the location of your confidential chassis identification number. As these are not required to be forwarded to the agency, I have taken the liberty of destroying them.

SINCERELY,

ENCLS.

ASTON MARTIN LAGONDA (1975) LIMITED

Frederic Schwartz Officer of the Chief Counsel, N.T.S.A.,

JULY 31, 1980

Dear Mr. Schwartz,

Vehicle Identification Numbering (17 characters)

Please find enclosed details upon which the Aston Martin Lagonda (1975) Ltd.

company has based its vehicle identification number (VIN) system, to be introduced with our 1981 model year cars.

The following documents have been enclosed to help clarify and explain the construction of the VIN system in detail:

(a) Construction drawings B97-16204/5/6 apply to Aston Martin V8 Saloon, Volante and Vantage (LHD) models respectively, B97-16224 applies to the Lagonda (LHD) (not currently certified in USA).

(b) Engineering Instruction number 205 gives a detailed explanation of the VIN construction. Engineering Instructions are sent to various departments within the Aston Martin organization and act as a reference and guide upon which work is carried out.

(c) Drawings A97-16226 and A97-16544 show the VIN plate designs and locations on the vehicle. The VIN is also stamped on the chassis member in characters with a minimum height of 7 mm (0.28 inches), Figures 1 and 2 in Engineering Instruction 205 show the location.

We have not sent details of our VIN system to anyone else, therefore we would appreciate your forwarding this letter and its contents to the relevant U.S. department, or advising accordingly.

KINDEST REGARDS,

R. Goldsmith Certification Engineer Safety and Emissions Department

ENGINEERING INSTRUCTION no. 205

Vehicle Identification Number (VIN) Systems

1. INTRODUCTION

AML will soon be operating two distinct Vehicle Identification Number (VIN) systems, one system applying to cars sold to U.S.A. and Canada and the other system applying to cars sold elsewhere in the world.

2. U.S.A. AND CANADA VIN SYSTEM (NHTSA)

1981 and subsequent model year cars sold to U.S.A. and Canada are required to have a 17 (seventeen) character vehicle identification number assigned. This means a series of arabic numbers and roman letters assigned to each motor vehicle for identification purposes and shall be sans sarif type face with a minimum height of 4 mm.

The VIN shall appear clearly and indelibly (i.e. stamped) on:

(a) the vehicle certification label (i.e. the brass plate, part number A97-13074, fixed to left hand 'B' post), and

(b) the VIN label part number A97-16226 and fixed in the same manner and position as the superceded label, part number 071-50-0160, on the dashboard.

2.1 VIN Content and Structure The VIN content and structure is as follows:

STRUCTURE

RACTER POSITION

1)

2) Assigned by BSI

3)

4) Gross vehicle weight class. 'C' = 4001 to 5000 lbf 'D' = 5001 to 6000 lbf

5)

6) Model

7 Not used

8 Model variant

9 Check digit (see R.G.'s memo for detailed explanation)

10 Model Year. 'A' = 1980

11 Plant of manufacture. 'T' = Tickfords

12 Driving position. 'T' = (Illegible Words) A = 1 J = 1 T = 3 B = 2 K = 2 U = 4 C = 3 L = 3 V = 5 D = 4 M = 4 W = 6 E = 5 N = 5 X = 7 F = 6 P = 7 Y = 8 G = 7 R = 9 Z = 9 H = 8 S = 2

VIN: S C F C V 8 0 S A Assigned value: 2 3 6 3 5 8 0 2 0 1 Weight factor: 8 7 6 5 4 3 2 10 0 9 Product: 16 21 36 15 20 24 0 20 0 9

2.1.1 World Manufacturers Identifier (WMI) Section

The WMI section is located in character positions 1 to 3 inclusive and is assigned by B.S.I. The code for all our models is SCF.

2.1.2 Vehicle Description Section (VDS)

The VDS is located in character positions 4 to 8 and is assigned by the manufacturer within the constraints laid down in the USA Federal Register, volume 44, number 57.

2.1.3 Vehicle Indicator Section (VIS)

The VIS is located in character positions 10 to 17 inclusive and is also assigned by the manufacturer within the constraints in the Federal Register.

2.1.4 The Check Digit

The check digit shall be determined and included in the VIN for each car sold to North America and Canada. It is determined by carrying out a mathematical computation that utilises each of the VIN characters according to the following formula:

(a) Each alphabetic character is assigned a numeric value according to the following table:

(b) The assigned value for each character is then multiplied by a weight factor that is dependent on VIN character position, see worked example below.

(c) The products are then added together and the sum divided by 11.

(d) The check digit is the remainder of the division, when this is 10 the check digit is X; when zero the check digit remains zero.

Worked example

VS Saloon (LHD) with assumed chassis number 12456 VIN: T L 1 2 4 5 6 Assigned value: 3 3 1 2 4 5 6 Weight factor: 8 7 6 5 4 3 2 Product: 24 21 6 10 16 15 12

Sum of products = 265, divide by 11 = 24 1/11

*Thus the check digit = 1 (to be inserted in ninth character of VIN)

2.1.4.1 Check Digit - Simplification

Because many of the VIN characters are common to each model the check digit

The scheme works thus:

(a) The Intermediate Check Digit remains constant for each model variant.

(b) Having allocated the sequential chassis number, multiply each digit by its weight factor and add these products to find the sum.

(c) Referring to Table 1(a), line-up the appropriate Sum and read across to the next column for the Sequential Number Check Digit (SCD).

(d) Next, refer to Table 1(b), and in the first column line-up the Sequential Number Check Digit, then line-up the Intermediate Check Digit; the point where the column and rows intercept is the corresponding VIN Check Digit.

(e) A worked example of the simplified Check Digit determination is shown below.

V8 SALOON APPROX. LHD

VIN Prefix Sequential Chassis No.

SCFCV80S ATL12678

4 3 2

Sum = 61 = 24+21+16

Sequential No. Check Digit = 6 [From Table 1(a)]

Intermediate Check Digit = 2

VIN Check Digit = 8 (Illegible Words)

(f) A summary of the Intermediate Check Digits for our model range is listed below: Model Driving Intermediate Instruction Drawing position Check Digit Number V8 Saloon Left HD 2 B97-16204 " Right HD 0 B97-16211 V8 Volante Left HD 5 B97-16205 " Right HD 3 B97-16212 V8 Vantage Left HD - B97-16206 " Right HD 8 B97-16213 Lagonda Left HD 4 B97-16224 " Right HD 2 B97-16225

* APPLICABLE (Illegible Words) VIZ (Illegible Words)

3. VIN SYSTEM - BEST OF THE WORLD (i.e. not applicable to USA or Canada)

The vehicle identification number (VIN) section on the brass plate, part numbers A97-15564/5 applicable to the Lagonda and V8 models respectively, will be completed by AML using the current sequential chassis numbering system. The plates will be embossed using stamps with a character of 4 mm minimum height. There will be no gaps or marks between the characters. The number will be finished with a dash, again without a gap, similar to the start of the number as shown in drawing A97-15564/5.

The chassis numbering (VIN) system is as follows:

(a) Lagonda : -LOOR13XXX-

(b) V8 Saloon : -V8SOR12XXX-

(c) V8 Volante : -V8COR15XXX- and (d) V8 Vantage : -V8VOR12XXX-

3.1 Lagonda VIN Structure Lagonda VIN Structure CHARACTER POSITION 1 -L Model 2 0 Not yet designated 3 0 Not yet designated, but J to be used for cars sold to Japan 4 R R = Right hand drive; L = Left hand drive 5 1) Chassis number model variant prefix 6 3) 7 X) 8 X) Sequential chassis number 9 X-

3.2 V8 VIN Structure V8 VIN STRUCTURE CHARACTER POSITION 1 -V) Model 2 8) 3 S,C or V Variant, i.e. S = Saloon; C = Convertible & V = Vantage 4 0 Not yet designated, but 'J' to be used for care sold to Japan 5 R or L R = Right hand drive; L = Left hand drive 6 I) Chassis number model variant prefix 7 2 or 5) 8 X) 9 X) Sequential chassis number 10 X-

3.3 Location of VIN Chassis Stamping

Bearing in mind the points outlined in 3. above, the VIN will also be stamped in the RHS of the chassis in the locations indicated in Figures 1 and 2 applicable to the Lagonda and V8 models respectively. The character heights shall be a minimum 7 mm high, and the number shall be legible when the car is completed and ready for sale, i.e. not covered by underseal.

APPROVED BY: S. COUGHLIN

PREPARED BY: A. GOLDSMITH

SAFETY & EMISSIONS: J. D. ORCHARD

Table 1

(a) Sequential No. Check Digit (SCD) Sum SCD Sum SCD Sum SCD 1 1 36 3 71 5 2 2 37 4 72 5 3 3 38 5 73 7 4 4 39 6 74 8 5 5 40 7 75 9 6 6 41 8 76 10 7 7 42 9 77 0 8 8 43 10 78 1 9 9 44 0 79 2 10 10 45 1 80 3 11 0 46 2 81 4 12 1 47 3 13 2 48 4 14 3 49 5 15 4 50 6 16 5 51 7 17 6 52 8 18 7 53 9 19 8 54 10 20 9 55 0 21 10 56 1 22 0 57 2 23 1 58 3 24 2 59 4 25 3 60 5 26 4 61 6 27 5 62 7 28 6 63 8 29 7 64 9 30 8 65 10 31 9 66 0 32 10 67 1 33 0 68 2 34 1 69 3 35 2 70 4

(b) VIN Check Digit

Intermediate Check Digit (Illegible Table)

ID: 3232yy

Mr. Robert W. Smith
President
Auto Safety Corporation
Box 424
Middletown, Delaware 19709

Dear Mr. Smith:

This responds to your letter of October 14, 1991, to Taylor Vinson of this Office, asking for a confirmation of your interpretation of Motor Vehicle Safety Standard No. 108, based upon a meeting with Mr. Vinson on August 15, l990.

You are developing a license plate frame that incorporates a "flashing/steady burning stop lamp", for use on passenger cars and motorcycles, and "an auxiliary flashing/steady burning stop lamp" for use on vans, minivans, and pickup trucks. You cite a letter of this agency to Bettie Lou Simcox, dated October 24, 1986, as authority for your understanding that Standard No. l08 allows the use of a flashing, steady burning stop lamp.

Standard No. 108 covers original motor vehicle lighting equipment, and lighting equipment that is intended to replace the original lighting equipment. It does not cover supplementary or novelty lighting equipment offered in the aftermarket. Mrs. Simcox asked us about the acceptability of an aftermarket stop lamp which, when the brake is applied, pulses before going into a steady burning mode. We informed Mrs. Simcox that her lamp was unacceptable as replacement equipment because Standard No. l08 requires original equipment stop lamps, and lamps designed to replace that equipment, to be steady burning in use, but that it would be permissible under Standard No. l08 as a supplementary stop lamp. For the same reason, your invention would not be prohibited by Standard No. l08 if it is offered in the aftermarket as a supplementary stop lamp, which we understand is your intent.

You should be aware that Standard No. 108 specifically requires motor vehicles to be equipped with one or more license plate lamps. We are uncertain of the effect, if any, that the installation of your combination license plate frame/supplementary stop lamp would have upon conformance of a vehicle's license plate lamp(s) with the requirements of Standard No. l08. We therefore remind you of the prohibition in the National Traffic and Motor Vehicle Safety Act that a manufacturer, distributor, dealer or motor vehicle repair business may not render inoperative, in whole or in part, a device such as the license plate lamp that has been installed in accordance with a safety standard such as Standard No. 108. Sincerely,

Paul Jackson Rice Chief Counsel

ref:108 d:ll/l5/9l

ID: 6991

AIR MAIL

Mr. Charles Danis Les Enterprises Track Test Inc. 4652 Avenue Victoria Montreal, Quebec H3W 2N1 Canada

Dear Mr. Danis:

This responds to your letter about testing related to Federal motor vehicle safety standard No. 121, Air Brake Systems, (49 CFR 571.121). You explained that your company has recently conducted a compliance test on an articulated bus manufactured by MCI Greyhound Canada. According to your letter, the buses were tested using 28 psi for the brake actuation test and 40 psi for the brake release test. While these air pressures differ from the pressures specified in S5.3.3 and S5.3.4 for brake actuation and release times, you stated that MCI was relying on a July 23, 1976 interpretation issued by the agency to Mr. J.W. Lawrence of the White Motor Corporation that permitted such brake actuation and release pressures. We note that to be consistent with that interpretation, the maximum brake chamber pressure must have been 40 psi when the service reservoir pressure was at 100 psi. Your letter was not clear on that point. You asked whether this interpretation is still valid. As explained below, the answer is yes.

In its inquiry to NHTSA, White Motor Corporation asked whether S5.3.3 and S5.3.4 of Standard No. 121 require minimum brake chamber actuation and release time pressures of 60 psi and 95 psi, respectively, or whether these air pressures are included in the sections only as "bench marks" on which to base specifications for minimum actuation and release timing. In response, the agency's July 23, 1976 interpretation letter stated in relevant part that:

Your understanding that S5.3.3 and S5.3.4 only specify the air pressures of 60 psi and 95 psi as the basis for timing requirements is correct. Neither value is intended as a requirement that the vehicle be designed to provide a certain level of brake chamber air pressure. The values were based on an understanding of the typical configuration of existing air brake systems at the time the final rule was issued.

In response to your specific question, NHTSA's July 23, 1976 interpretation letter continues to be valid.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel Enclosure

Ref: 121 d:4/3/92

ID: nht91-5.38

DATE: September 6, 1991

FROM: None

TO: Taylor Vinson -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10-23-91 from Paul Jackson Rice (A38; Part 571.3)

TEXT:

This is to request confirmation of our interpretation that specific future vehicle models may be properly classified as multipurpose passenger vehicles (MPVs) for purposes of the Federal Motor Vehicle Safety Standards. Attachment I contains a description of these future vehicle models.

As described in Attachment I, the new models will be constructed on a truck chassis. The chassis-frame is separate from the vehicle body (a design usually associated only with trucks) and the chassis was originally designed to provide cargo-carrying capability as well as to permit rough road and off the road vehicle operation.

The vehicles also have special features for occasional off-road operation.

- Attachment I describes some of the special features for off-road operation.

- Attachment II shows a comparison of vehicle specifications for the new models (preliminary estimates) with characteristics listed in NHTSA's CAFE regulations which are used to identify vehicles capable of off-highway operation (minimum approach angle, departure angle, breakover angle, running clearance, and front and rear axle clearances). The new models are expected to meet the criteria for three out of the five off-highway vehicle characteristics listed.

- Attachment III shows a comparison of vehicle specifications for approach angle, departure angle, breakover angle, running clearance, and axle clearances for a variety of current model passenger cars and MPVs with estimated specifications for the new models. In general, the new models have specifications outside the range of most passenger cars and within or close to the range of most MPVs.

Because the future vehicle models described above are constructed on a truck chassis and have special features for occasional off-road operation, we believe that they would be properly classified as MPVs for purposes of the Federal Motor Vehicle Safety Standards. Please confirm that our interpretation is correct.

ATTACHMENT I

Description of Future Vehicle Models ATTACHMENT II

CAFE Regulation Minimum Preliminary Vehicle for Automobiles Capable Estimate for Characteristic of Off-Road Operation New Models

Approach angle 28 degrees Departure angle 20 degrees Breakover angle 14 degrees Running clearance 203 mm Axle clearance Front 178 mm Rear 178 mm

ATTACHMENT III

Charts and graphs showing vehicle specifications. (Graphics omitted)