Interpretation ID: aiam2312
Assistant Manager
Safety & Environmental Activities
American Honda Motor Co.
Inc.
P.O. Box 50 -- 100 W. Alondra Blvd.
Gardena
CA 90247;
Dear Mr. Gill: This is in response to your May 6, 1976, request for confirmation tha the Honda 'MPV' qualifies as a multipurpose passenger vehicle although it is constructed on a 'modified' truck chassis.; In our letter to you of April 30, 1976, we concluded that the Hond 'MPV' would be classified as a multipurpose passenger vehicle, based upon the assumption that the 'MPV' is constructed on a truck chassis. You responded that the 'MPV' is constructed on a 'modified' truck chassis, and questioned whether the National Highway Traffic Safety Administration considered this fact in its previous interpretation.; The reference to 'truck chassis' in the definition of multipurpos passenger vehicle, 49 CFR Part 571.3(b), is intended to include chassis that were designed and developed for trucks, but which have been produced in a version for use in passenger carrying vehicles. According to your letter and drawings of March 1, 1976, the Honda 'MPV' is a passenger version of the Honda TN 500 light truck. Since the modification of the chassis in the production of the 'MPV' does not appear to be so great that the major characteristics of the truck chassis are destroyed, we confirm our previous determination that the Honda 'MPV' qualifies as a multipurpose passenger vehicle.; Sincerely, Stephen P. Wood, Assistant Chief Counsel