Interpretation ID: aiam2188
Director
Vehicle Safety
Jeep Corporation
14250 Plymouth Road
Detroit
MI 48232;
Dear Mr. Perkins: This responds to Jeep Corporation's October 16, 1975, petition t initiate rulemaking to amend the present definition of 'Unloaded vehicle weight' (49 CFR S571.3) which reads:; >>>'Unloaded vehicle weight' means the weight of a vehicle with maximu capacity of all fluids necessary for operation of the vehicle, but without cargo or occupants.<<<; Jeep requests that the definition be amended to 'indicate that th unloaded vehicle [weight] does not include work-performing accessories which may be available as original equipment accessories.' The Jeep petition argues that the impracticality of conducting some dynamic testing with 'work-performing accessories' in place may force the discontinuance of some factory-installed accessories although factory installation may be more safe than a subsequent aftermarket installation.; The Jeep Corporation petition is denied. As a general matter, the NHTS has established that a vehicle which is designed to accept an optional component must be capable of meeting all applicable standards with the component installed. The NHTSA has evaluated the potential problems of dynamic testing with heavy or protruding accessories in place and concludes that a decision on the practicality and wisdom of so doing should be made on a 'standard-by-standard' basis. As you noted, the NHTSA has provided for removal of work-performing accessories in conducting compliance tests under Standard No. 219, *Windshield Zone Intrusion*. If Jeep considers dynamic testing in other standards to be unjustifiably burdensome because of the necessity of testing with all accessories in place, it would be appropriate to petition for rulemaking to amend the standard in question.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;