Interpretation ID: aiam1027
Recreational Vehicle Institute
Inc.
Suite 406
1140 Connecticut Avenue
Washington
DC 20006;
Dear Mr. Humphreys: This is in reply to your letter of February 2, 1973, in which you as whether a vehicle designed to provide living accommodations for persons, but also designed to carry more than 10 persons, will be considered a motor home (a multipurpose passenger vehicle) or a bus under the motor vehicle safety standards. You question arises in the context of whether such a vehicle must comply with Standard No. 217, Bus Window Retention and Release.; Based on the definitions of these vehicle types in Part 571 of Titl 49, Code of Federal Regulations, we would consider this vehicle to be a bus. A multipurpose passenger vehicle, in which category a motor home falls (49 CFR 571.205), is limited to being designed to carry 10 persons or less. As the vehicle in question is designed to carry more than 10 persons, it must, under these definitions, be considered a bus.; Moreover, we do not believe there is a legitimate basis to exempt thi vehicle from Standard No. 217. That standard is intended to require vehicles designed to carry more than 10 persons to have specific provisions for the emergency escape of passengers. This purpose is not offset in cases where the vehicle simultaneously provides living accommodations.; We believe this conclusion to be consistent with the exemption provide in Standard 217 for limousines and station wagons. These vehicles, which like the vehicle in question are ordinarily vehicle types other than buses, are exempt because sufficient means of emergency escape are otherwise available. There is no indication that such is the case in the vehicle which is the subject of your letter.; Yours truly, Richard B. Dyson, Assistant Chief Counsel