ID: nht81-1.48

DATE: 03/17/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Society of Automotive Engineers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Leo P. Ziegler, Jr. Manager, Motor Vehicle Safety and Environment Program Society of Automotive Engineers, Inc. 400 Commonwealth Drive Warrendale, PA 15096

Dear Mr. Ziegler

This is in response to your letter forwarding your firm's vehicle identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115 -Vehicle identification number.

The National Highway Traffic Safety Administration (NHTSA) does not give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.

Sincerely,

Frank Berndt Chief Counsel

December 18, 1979

Mr. Howard H. Magor President Aluminum Body Corporation P.O. Box 40 Montebello, CA 90640

Dear Mr. Magor

I am in receipt of a copy of your November 30, 1979 letter to the National Highway Traffic Safety Administration with regard to the assignment of a World Manufacturer (Maker) Identifier (WMI) Code for Aluminum Body Corporation. I am therefore, as the USA national authority, making the following assignments:

Aluminum Body Corporation ? W. Washington Blvd. Montebello, CA 90640 UNITED STATES

1 & 9 (With the 3rd, 4th, & 5th characters of the Vehicle Identifier Section to be: 0 0 8)

Commercial Trailer

If you have any questions regarding the above assignment, please do not hesitate to contact me.

Sincerely yours,

Leo. P. Ziegler, Jr. Manager, Motor Vehicle Safety and Environment Program

jeh

cc: M. W. Dixon K. F. Erickson, NHTSA R. P. Hickey

ID: nht81-1.49

DATE: 03/17/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Friedman and Medalie

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Leonard A. Fink Attorney at Law Friedman and Medalie 1899 L Street, NW Washington, D.C. 20036

Dear Mr. Fink:

This is in response to your letter forwarding your firrm's vehicle identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115 -Vehicle identification number.

The National Highway Traffic Safety Administration (NHTSA) does not give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.

Sincerely,

Frank Berndt Chief Counsel

December 4, 198O

Administrator National Highway Traffic Safety Administration 400 Seventh Street, N.W. Washington, D.C. 20590

Attn: VIN Coordinator

Gentlemen:

On behalf of our client, Steyr-Daimler-Puch A.G., and in accordance with FMVSS 115, we furnish the following information regarding the VIN number code to be used by our client:

ID: nht81-1.5

DATE: 01/22/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Hendrickson Mfg. Co.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your November 25, 1980, letter asking whether any safety standards have been violated by a truck modification that you perform. In your modification, you alter a chassis to provide right-hand controls. The vehicle is then sent to a final-stage manufacturer for completion.

As an incomplete vehicle manufacturer, you are required to attach the appropriate label to the vehicle in accordance with Part 567, Certification. That label makes certain statements about the compliance of the vehicle with safety standards as a result of your modifications.

You ask whether any safety standards have been violated by your modifications. It is impossible for the agency to determine compliance without testing one of your vehicles. You list several changes that you make to the vehicle, including the addition of: a foot throttle, foot service brake, hand spring brake, turn signal, transmission selector, and steering wheel. The agency has safety standards that govern many of these devices. These standards are found in Volume 49 of the Code of Federal Regulations, in Part 571. It is a manufacturer's responsibility to ensure that its vehicles comply with these standards. The only advice that we can offer is that nothing precludes the type of modifications that you propose. The installation of right-hand controls is permissible as long as the compliance with all safety standards is maintained.

ID: nht81-1.50

DATE: 03/17/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Aston Martin Lagonda, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. R. Goldsmith Certification Engineer Safety and Emissions Department Aston Martin Lagonda, Ltd. Tickford Street, Newport Pagnell Buckinghamshire MK 16 9AN

Dear Mr. Goldsmith

This is in response to your letter forwarding your firm's vehicle identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115 -Vehicle identification number.

The National Highway Traffic Safety Administration (NHTSA) does not give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.

Sincerely,

Frank Berndt Chief Counsel

Mr. F. Berndt, Chief Counsel, U.S. Department of Transportation, National Highway Traffic Safety Administration, Washington D.C. 20590, U.S.A. 11th December, 1980

Dear Mr. Berndt, Vehicle Identification Numbers

Thank you for your letter of 18th November, in which you indicate that Vehicle Identification Number (VIN) deciphering information is made available to the public. I would like to point out that only the brake horse power (BHP) data is confidential, not all the engine type information.

However, as you suggest, I have reviewed the engine type information by deleting the BHP data, and adding the vehicle make, model and manufacturer's name.

None of the information in the VIN decipher is now confidential but complete vehicle identification is readily available. Thus please find enclosed herewith the Aston Martin Lagonda resubmission of the VIN constructed to Federal Motor Vehicle Safety Standard No. 115.

Yours sincerely,

R. Goldsmith Certification Engineer Safety and Emissions Department

RG/JL

copy Aston Martin Lagonda Inc., U.S.A.

ID: nht81-1.6

DATE: 01/22/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Shanghai No. 1 Rubber Plant

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 17, 1980 letter in which you requested information about the steps your manufacturing plant must take to comply with this agency's requirements for selling tires in the United States. Your letter stated that your main products are truck tires.

All truck tires (for both light and heavy-weight vehicles) imported into the United States must comply with Federal Motor Vehicle Safety Standard No. 119 (49 CFR @ 571.119). I have enclosed a copy of this standard for your information. You will see that the standard specifies performance requirements (strength, endurance, and high speed performance), marking requirments (treadwear indicators and labeling information), and tire and rim matching information requirements.

Concerning the performance requirements, your letter asked how many sets of each tire size must be delivered to this agency for testing and how the costs are paid. The European nations require manufacturers to deliver tires for testing before they can be sold, but this country does not. For our purposes, the manufacturer itself must certify that its tires comply with the requirements of Standard No. 119. After the manufacturer determines that the tires comply with the requirements, the manufacturer stamps the letters "DOT" on the tire to accomplish the certification. This agency then makes spot checks of tires, by purchasing some from a dealer and testing the tires according to the procedures set forth in Standard 119. If the tires pass the tests, no further steps are taken. However, there is no advance approval procedure by the agency.

It is a simple matter to check the tire to see that the marking requirements have been followed. I should note that the U.S. Customs Service will not allow tires without a DOT marking to enter the United States.

With respect to the tire and rim matching, this information, as well as the loading schedules for the tire size (showing the maximum load the tire can carry at designated inflation pressures) must either be set forth in a current trade association manual or be furnished by manufacturers to dealers of the tires and in duplicate to this agency. If you wish to obtain a copy of the current manual published by the American tire manufacturers to see if the tire sizes manufactured by your plant are listed therein, you may send $ 8.50 plus postage costs to: The Tire and Rim Association, 3200 West Market Street, Akron, Ohio 44313. If the tire sizes and corresponding rims which you manufacture are listed in that manual, you have complied with this requirement. If the sizes are not listed, you may consult other trade associations, or you may exercise the option to furnish the information to your dealers and to this agency.

I am enclosing a copy of another regulation that would also apply to your tires, 49 CFR Part 574, Tire Identification and Record Keeping. This requires every tire sold in this country to be labeled with certain information (see @ 574.5), including the manufacturer's identification mark. To obtain an identification mark, you should follow the steps set forth in @ 574.6 of this regulation.

Further, this regulation requires each manufacturer to furnish forms to its tire dealers to record the names and addresses of the first purchasers of these tires. The dealers must then return the completed forms to the tire manufacturer, or some party designated by the manufacturer to receive these forms. This is necessary in case the manufacturer must recall the tires because they fail to comply with Standard 119 or because the tires have a safety-related defect. It may be necessary for you to make arrangements with some party in this country to store the completed forms for you.

Finally, I am enclosing a procedural rule, which applies to all parties subject to the regulations of this agency (49 CFR Part 551). This regulation requires all manufacturers to designate a permanent resident of the United States as the manufacturer's agent for service of process in this country. The agent may be either an individual or a business entity. This designation must be in writing and in a form which is valid and binding under Chinese law. Such designation must provide the information set forth in @ 551.45(b) and be mailed to: Administrator, National Highway Traffic Safety Administration, U.S. Department of Transportation, 400 Seventh Street, S.W., Washington, D.C. 20590.

I hope that this information helps you and that the trade relationship between our countries will be a long and fruitful one. If you need any further information, or clarification of some of the information set forth in this letter, please do not hesitate to contact me.

SINCERELY,

November 17, 1980

Tire Division, National Highway Traffic Safety Administration of Department of Transportation,

Dear Sirs:

Our plant is Shanghai No. 1 Rubber Plant, formally Ta Chung Hua Rubber INd.Co., established in 1928. Its main products are truck tires and light truck tires, "DOUBLE COIN" brand.

Since liberation, our products have already been exported to many other countries and districts. For promoting Sino-American trade, we would interest to export our tires (bias-ply) into the U.S. market.

We have been told that truck tires imported into U.S. market must meet the minimum Standards of NHTSA of DOT and get his identification. As we are short of further information related to these tests, we write this letter to you for your kind assistance. It would be much appreciated if this letter will soon reply to us for the following matters:

1) How many NHTSA Standards must be met before entering to U.S. tire market?

2) How many sets of each tire size will deliver to NHTSA for total testing procedures?

3) How many testing fee would be paid, if it is nessesary to?

4) Further details which we have to know.

Deng Shin-Wen, Deputy director & chiefengineer

ID: nht81-1.7

DATE: 01/22/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Convenient Machines Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 22, 1980, asking "acceptance" of the CUB three-wheeled vehicle "for import certification."

We confirm the advice given you by Mr. Vinson of this office in your recent telephone conversation with him. The CUB is classified as a "motorcycle" for purposes of compliance with the Federal motor vehicle safety standards. If CUBs are manufactured to comply with all standards applicable to motorcycles (see Title 49 Code of Federal Regulations, Part 571), and have a label permanently attached certifying that fact (49 CFR 567), this is all that is needed to fulfill the requirements of this agency for importation and sale in the United States, under the joint regulations issued by the Departments of Transportation and Treasury (19 CFR 12.80).

If, in advance of regular production, you wish to import several noncomplying vehicles for purposes of test or experimentation, this is allowable, provided that at the time of entry a statement is attached to the declaration form that will be given the importer, stating the purpose for which the vehicle is being imported, the estimated time it will be on the public roads, and the disposition that will be made at the end of the period allowed (one year, renewable upon request). (19 CFR 12.80(b)(1)(vii)).

SINCERELY,

December 22, 1980

National Highway Traffic Safety Administration Office of Chief Council

Following my recent telephone conversation with you, and at the suggestion of Mr. John Carson, we are enclosing photographs and preliminary specifications of our C.B. "CUB" 3 wheeled 2 passenger I.E.C. powered vehicle.

These vehicles will be manufactured in Taiwan for Convenient Machines Inc. We intend to distribute and sell them in the United States following the gradual start of production in March 1981.

We understand that at the present time this vehicle is classified as a 3 wheeled motorcycle. We intend to full comply with the standards and regulations for this classification of vehicle as outlined in the TITLE 49 CODE of REGULATIONS as necessary for a certificate of acceptance for U.S. Customs entry purposes.

The attached photographs show the #1 prototype "CUB" on which certain further improvements are now in work. A more final version is shown in the 1/10th scale 4 view layout which indicates a larger hatchback door and better lite and vent locations. We expect to have 3 samples of these approximately February 15 and several will then be brought here at that time.

We feel that this vehicle not only complies with the regulations but also offers a number of additional safety features which are highly desirable. These are fully described in the enclosed list of features and specifications.

After your review of this material will you kindly send us a letter relative to the acceptance of this vehicle for import certification. If you find there are any requirements omitted please advise us so we can take immediate steps to include them. We will greatly appreciate your reply at the earliest possible date as we are now tooling up for production to commence pending your approval.

If you have any further questions on any aspect of the "CUB" design and specifications please call me at 212 249 2424. I will be out of town from Dec 28 thru January 15 in which case you can contact Mr. Phil Prince at 212 594 6895.

We look forward to your approval of our compliance program on this vehicle and thank you for your cooperation.

Richard H. Arbib Vice President-Design

ID: nht81-1.8

DATE: 01/28/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Rolf Hahn

TEXT: This is in reply to your recent undated letter to George Ziolo of this agency seeking our assistance concerning the registration of your foreign-made car.

Specifically, you are a member of the German Military Representative in the United States who comes within the terms of Article IV of the NATO Status of Forces Agreement. As such, your German driver's license is accepted by the State of New Jersey where you presently reside. You have imported a car that does not meet Federal motor vehicle safety standards, as permitted by 19 CFR 12.80(b)(1)(vi), but the local authorities will not issue an inspection sticker to you, insisting that the car comply with all applicable Federal and State laws.

We believe that 15 U.S.C. 1392(d) (Section 103(d) of the National Traffic and Motor Vehicle Safety Act, copy enclosed) prohibits New Jersey from a refusal to register your car. That section provides that

"Whenever a Federal motor vehicle safety standard. . . is in effect, no State. . . shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle . . . any safety standard applicable to the same aspect of performance of such vehicles . . . which is not identical to the Federal standards."

Under regulations issued pursuant to 15 U.S.C. 1397(b)(4) by the Departments of Transportation and Treasury, the "temporary importation" of the car belonging to a member of the German Military Representative is allowed without the necessity of conforming it to U.S. Federal safety requirements (19 CFR 12.80(b)(1)(vi)), provided the importer declares at the time of entry that the car is imported for personal use and will not be sold. Thus, the car is exempted from meeting safety standards currently in effect that would otherwise apply to it. That exemption makes any State standards on the same aspects of performance, in effect, nonidentical to the Federal standards for that car. This means, in our view, that a State may not impose its own safety standards on the car as a prerequisite to registration where those standards cover the same aspects of performance as Federal ones.

Preemptive effect can also be found under general principles of preemption. Preemption is found where a State regulatory scheme conflicts with a Federal one. Conflict exists in this case because the Congressional purpose underlying the statutory authorization for temporary importation regulations is frustrated by State enforcement of Federal standards compliance with which has been excused under those regulations. That purpose would be similarly frustrated by State enforcement of State standards identical to Federal ones.

The provisions of 19 CFR 12.80(b)(1)(vi) under which your vehicle entered were inserted in the importation regulation at the request of the U.S. Department of State. We understood that international agreements (not identified by State) prohibited us from requiring compliance of certain categories of imported vehicles with U.S. safety standards. We therefore believe it possible that the issue of local registration of vehicles so exempted may also have been dealt with in these agreements.

ENC.

US Department of Transportation NHTSA ATTN: George J. Zislo

Dear Mr. Zislo:

In response to your telephone conversation with Mr. Fischer yesterday, I would like to give you more information concerning the registration of my foreign-made car.

I am stationed in New Jersey as a member of the civilian component of the Federal Republic of Germany on a temporary NATO assignment, as stated in the inclosed copy. Recently, I have imported my German-made car which I have registered with the New Jersey Division of Motor Vehicles, as a temporary resident of New Jersey, in compliance with applicable State laws. However, the local inspection station in Eatontown, NJ, did not issue an inspection sticker for my car. The local authorities insisted that my car complies with all applicable Federal and State laws. This opinion was also expressed by Mr. Arnone (Tel. No. 609-292-4873) of the New Jersey Division of Motor Vehicles in Trenton, NJ.

It is, however, my understanding that my special status as a member of a NATO Nation exempts my foreign-made car from compliance with any otherwise applicable Federal and State Motor Vehicle Safety Standards. This exemption is also stated in a letter of the US Department of Transportation to the German Military Representative, dated 13 December 1979, a copy of which I have inclosed for your information.

Based on the above information and the inclosed copies, I would like to request your office to confirm the exemption of my foreign-made car from any otherwise applicable Federal and State laws and to inform the New Jersey Division of Motor Vehicles accordingly.

Thank you very much for your help in this matter.

ROLF HAHN

FEDERAL REPUBLIC OF GERMANY ARMED FORCES ADMINISTRATIVE AGENCY

April 15, 1980

C E R T I F I C A T E No.: 1568/80

concerning Driver's Licenses for German personnel coming under the terms of the "Agreement between the Parties to the North Atlantic Treaty Regarding the Status of their Forces"

The member countries of the North Atlantic Treaty Organization (NATO) to which also the United States of America and the Federal Republic of Germany belong, have concluded an agreement concerning the status of the Armed Forces of one member country within the territory of another member country. This NATO Status of Forces Agreement entered (Illegible Words) treaty on August 23, 1953 (TIAS 2846).

My office has been directed by the Federal Republic of Germany to handle on behalf of the German side matters concerning the a/m agreement and to confer with the proper U.S. authorities in this field.

I, therefore, confirm that Mr. Rolf Hahn, born on May 19, 1944 being a member of The German Military Representative in USA/CA is a member of the (Illegible Word)/Civilian Component of the Federal Republic of Germany, and as such comes within the terms of (Illegible Words) Status of Forces Agreement.

Mr. Rolf Hahn is stationed in New Jersey (Illegible Words) of his NATO duties which he performs on behalf of the Government of the Federal Republic of Germany within the United States of America. According to the letter of the State of New Jersey, Department of Law and Public Safety, Division of Motor Vehicles, dated March 8, 1965, driver's licenses of (Illegible Word) of the Armed Forces and of the Civilian Component of other NATO countries are accepted by the State of New Jersey.

Since Mr. Rolf Hahn is in right for possession of German Driver's License No. 5/4890/68, issued on Nov. 1, 1968 by the city/of Berlin, Germany, he does in accordance with the enclosed letter of the State of New Jersey of March 8, 1965, not require a Driver's License issued by this state.

H.D. Borowski

Legal Adviser, Deputy Chief

Administrative Office with the German Military Representative in USA and Canada

ID: nht81-1.9

DATE: FEBRUARY 3, 1981

FROM: J. KAWANO -- GENERAL MANAGER, U.S. REPRESENTATIVE OFFICE-TOYOTA

TO: FRANK BERNDT -- NHTSA CHIEF COUNSEL

TITLE: INTERPRETATION OF FEDERAL MOTOR VEHICLE SAFETY STANDARD NO. 105-75

ATTACHMT: OCTOBER 3, 1988 LETTER FROM JONES TO BURKARD, EBNER, AND TEVES, OCTOBER 9, 1981 LETTER FROM BERNDT TO KAWANO, JULY 10, 1974 LETTER FROM DYSON TO NAKAJIMA, MAY 24, 1974 LETTER FROM TEVES TO GREGORY, AND MAY 27, 1988 LETTER FROM TEVES TO JONES

TEXT: Toyota is currently considering a new type of brake reservoir, as shown in Fig. 1, in accordance with your letter enclosed herewith as Attachment #1.

We request clarification of our interpretation of @5.4.2 & 5.3.1 of FMVSS No. 105-75, concerning this type of brake reservoir.

S5.4.2 reads as follows:

Reservoirs, whether for master cylinders or for other type systems, shall have a total minimum capacity equivalent to the fluid displacement resulting when all the wheel cylinders or caliper pistons serviced by the reservoirs move from a new lining, fully retracted position (as adjusted initially to the manufacturer's recommended setting) to a fully worn, fully applied position, as determined in accordance with S7.18(c) of this standard. Reservoirs shall have completely separate compartments for each subsystem except that in reservoir systems utilizing a portion of the reservoir for a common supply to two or more subsystems, individual partial compartments shall each have a minimum volume of fluid equal to at least the volume displaced by the master cylinder piston servicing the subsystem, during a full stroke of the piston.

As far as our new type of brake reservoir is concerned, we recognize that if the following three conditions were satisfied, these reservoirs would conform to S5.4.2. Is this interpretation correct?

i) W + X + Y > C + D + E *

ii) X > A

iii) Y > B

* (Note: A vehicle equipped with this type of reservoir can be expressed as W+X+Y>C+D, since E is equivalent to zero.)

W; common capacity for fluid of front brake, rear brake & clutch as hatching part in Fig. 1

X; a compartment capacity for front brake fluid Y; a compartment capacity for rear brake fluid

A; volume displaced by front master cylinder during a full stroke of position

B; volume displaced by rear master cylinder during a full stroke of position

C; front capacity of fluid when all cylinder pistons serviced by the reservoirs from a new lining, fully retracted position to fully worn, fully applied position

D; rear capacity of fluid when all cylinder pistons serviced by the reservoirs from a new lining, fully retracted position to fully worn, fully applied position

E; clutch capacity of fluid when all cylinder pistons serviced by the reservoirs from a new lining, fully retracted position to fully worn, fully applied position

In accordance with the aforementioned interpretation, we recognize that if the warning level is not less than the level of 1/4 (W+X+Y), S5.3.1 would be satisfied. This "W" is the same volume as the "W" in expression i) of inequality. Is this interpretation correct? The main point in question is whether the "W" in expression i) of inequality can be considered the capacity in a case where the overall compartment system -- clutch included -- has not failed. We illustrate such a case in te hatching segment of Fig. 1.

We would appreciate a reply at your earliest convenience. If you should have any comments or questions, please contact Mr. M. Mori, a member of my staff, who can be reached at: (201) 865-2019. Thank you.

Enclosure.

Fig. 1. Warning level.

ID: nht81-2.1

DATE: 03/17/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Columbia Body & Equipment Co.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Ms. Joan Morton Bookkeeping Department Columbia Body & Equipment Co. 123 N.E. Oregon Street Portland, OR 97232

Dear Ms. Morton

This is in response to your letter forwarding your firm's vehicle identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115 -Vehicle identification number.

The National Highway Traffic Safety Administration (NHTSA) does not give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.

Sincerely,

Frank Berndt Chief Counsel

November 25, 1980

Administrator National Highway Traffic Safety Administration 400 7th Street S.W. Washington, D.C. 20590

ATTENTION: VIN COORDINATOR Ref: Per conversation with Frederick Schwartz 11-24-80 Gentlemen:

Per Motor Vehicle Safety Standard Part 571, S6, Page 17500 reporting requirements, the following is an explanation of Columbia Body & Equipment Co.'s assigned values in regards to the 17 character vehicle identification number as called for by the amendment to Safety Standard 115.

POSITION 1 = 1

POSITION 2 = B (These characters uniquely identify C.B.E. as the Manufacturer - Registered with SAE) see attached letter

POSITION 3 = 9

POSITION 4 = (Type of Trailer) A - Pintle type Pull, B - Full, C -Gooseneck 5th Wheel, D - Straight Semi, E - Ball Type Pull, F -Custom

POSITION 5 = (Body Type) A - Utility, B - Van Body, C - Flat Bed D -Dump, E - No Body

POSITION 6 = (Trailer length) consecutively - example: 09 - 9' Long,

POSITION 7 = 10 - 10' Long, 11 - 11' Long etc. all lengths are rounded to the nearest foot.

POSITION 8 = (Axle Configuration) or number of axles. 1 - 2 - 3 -4 -5 etc.

POSITION 9 = Check Digit Number

POSITION 10 = (Model Year) - A - '80, B - '81, C - '82, D - '83 etc.

POSITION 11 = (Plant of Manufacture) - P - Portland

POSITION 12 = (C.B.E.'s unique identifiers as registered through SAE)

POSITION 13 = Consecutively - see attached letters

POSITION 14 = 018 - Specialty Trailers/Commercial Trailers 003 - Pony Trailer/Commercial Trailers 004 - Belly Dump Trailer/Commercial Trailers

POSITION 15 = (Represents the number sequentially assigned by C.B.E. to

POSITION 16 = each new trailer) Consecutively 368, 369, 370, etc.

POSITION 17 =

Please acknowledge if the above is correct. I have enclosed a carbon copy of this letter to be returned to me with a place for you to sign and a self addressed envelope for your convenience. Thank you.

Very truly yours,

COLUMBIA BODY & EQUIPMENT COMPANY

Joan Morton Bookkeeping Dept.

March 1, 1979

Mr. Thomas J. Hickman Columbia Body and Equipment Co. 123 N. E. Oregon Street Portland, OR 97232

Dear Mr. Hickman:

Thank you for your completed application form for the assignment of World Manufacturer Identifier (WMI) Codes. We would like to confirm the following assignments:

Columbia Body and Equipment Company 123 N.E. Oregon Street Portland, Oregon 97232 UNITED STATES 1 B 9 (with 3rd, 4th, and 5th characters of Pony Trailer/ Vehicle Identifier Section to be 0 0 3) Commercial Trailer

1 B 9 (with 3rd, 4th, and 5th characters of Belly Dump Trailer/ Vehicle Identifier Section to be 0 0 4) Commercial Trailer

Sincerely,

Leo P. Ziegler, Jr.

Manager, Motor Vehicle Safety and Environment Program

pd

cc: M. Dixon D. Wolfslayer

November 3, 1980

Ms. Joan Morton Columbia Body & Equipment Company 123 N.E. Oregon Street Portland, Oregon 97232

Dear Ms. Morton:

This letter confirms our recent telephone conversation on the assignment of a World Manufacturer (Maker) Identifier (WMI) Code. As the agent of the NHTSA for the assignment of manufacturer identifiers pursuant to S 4.5.1 of FMVSS 115, we hereby confirm the following code:

Columbia Body & Equipment Company 123 N.E. Oregon Street Portland, Oregon 97232 UNITED STATES

1 B 9 with teh 3rd, 4th & 5th characters of the Vehicle Indicator Section to be 0 1 8

Specialty Trailers/Commercial Trailers

Yours truly,

Leo P. Ziegler, Jr. Manager, Motor Vehicle Safety and Environment Program

LPZ/dms

cc: M. W. Dixon N. F. Erickson B. P. Hickey

ID: nht81-2.10

DATE: 03/25/81

FROM: FRANK BERNDT -- NHTSA CHIEF COUNSEL

TO: STEPHEN W. MATSON -- TRIAD SERVICES INC.

TITLE: NOA - 30

ATTACHMT: LETTER DATED 03/10/81 FROM STEPHEN W. MATSON TO NHTSA STD. 108

TEXT: Dear Mr. Matson:

This is in reply to your letter of March 10, 1981, asking whether the placement of a clear lens cover in front of a motorcycle headlamp would be permissible under Federal Motor Vehicle Safety Standard No. 108.

SAE Standard J580 (both a and b versions) Sealed Beam Headlamp Assembly is incorporated by reference in Tables I and III of the standard as one of the standards pertaining to headlamps lamps for use on passenger cars, trucks, buses, and multipurpose passenger vehicles. Paragraph 5.2 of J580 states that, "When in use, a headlamp shall not have any styling ornament or other feature, such as a glass cover or grill, in front of the lens."

The principal referenced SAE material for motorcycle headlamps is J584a Motorcycle Headlamps. As options, both J584 and S4.1.1.34 of Standard No. 108 allow, in effect, a motorcycle to be equipped with one half of any sealed beam system permissible on four-wheeled motor vehicles. We therefore view the prohibition of J580 as applicable to use of any sealed beam headlamp, regardless of the type of vehicle on which it is installed.

Paragraph S4.1.3 of Standard No. 108 forbids the installation of additional equipment "that impairs the effectiveness of lighting equipment required" by Standard No. 108. Because of moisture accumulation, discoloration, cracks, etc., a glass or plastic cover might tend over a period of time to diminish or distort the headlamp beam. This is of particular concern with reference to the unsealed headlamps implicitly permitted by SAE J584 because of the tendency of the reflector to deteriorate with age.

2

The agency therefore has concluded that no motorcycle headlamp may have a glass shield in front of it when in use.

Sincerely,