Interpretation ID: 1983-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 03/04/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: E- Z- Go Textron

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 4, 1983, telling of your wish to build a four-wheeled light weight traffic enforcement vehicle similar to a three-wheeled machine manufactured by Cushman. You have asked whether you have to meet passenger car safety standards "or can we obtain a waiver for this vehicle only to comply with motorcycle safety standards?" You have enclosed a brochure on the vehicle you propose to modify, Textron's GX-800.

I am sorry to say that only vehicles with three wheels or less are defined as "motorcycles" for purposes of compliance with the Federal motor vehicle safety standards. Years ago, the agency totally excluded from the application of those standards four-wheeled vehicles with a curb weitht of 1000 pounds or less such as the GX-800. However, that exclusion was terminated in the early 1970's.

A manufacturer of 10,000 vehicles or less per year may petition for a temporary exemption from any safety standard where immediate compliance would cause substantial economic hardship. However, he must make a good faith effort to bring the vehicle into compliance during the exemption period. Although this would appear impossible with your vehicle because of its physical limitations, the agency has in the past exempted replicas of 1900-style vehicles where full compliance was manifestly not feasible. I enclose a copy of Title 49 Code of Federal Regulations Part 555 which sets out the exemption procedures. If your planned vehicle would have a cargo box, similar to the one on the Cushman vehicle, your vehicle could be considered a "truck" for compliance purposes.

As a car or truck, your vehicle would also have to comply with Federal fuel economy and emissions standards. Exemptions from fuel economy standards may be sought under 49 CFR Part 525. As to the emissions standards, you should write the Environmental Protection Agency.

ENC.

February 4, 1983

Ed Glancy Office of Chief Council National Highway Traffic Safety Adm.

Dear Mr. Glancy:

I have proposed that E-Z-Go Division of Textron Inc. build and market a traffic enforcement vehicle similar to the Cushman police vehicle (see enclosure).

I also propose that this vehicle should be a four wheeled vehicle for greater stability rather than a three wheeled vehicle.

This vehicle would be a modification of one of our current vehicles with the addition of a cab, rear bed enclosure, four wheel brakes, hand parking brake, larger diameter "DOT" tire, complete "DOT" lighting package, windshield wipers, seat belts, and a top speed of 35 M.P.H. (see our brochure).

My question is: Do we have to comply with automobile safety standards or can we obtain a waiver for this vehicle only to comply with motorcycle safety standards?

This vehicle would be sold primarily to city governments.

Thank you very much for your attention to this proposal.

John C. Dobbs Project Engineer

EZ-GO TEXTRON

Police Vehicle GASOLINE/ON-ROAD *

To the police officer or security patrolman, productivity takes on a more significant meaning. To provide security, the patrol vehicle must not only save steps and work, but it must be reliable enough to assure that the officer is in the right place at the right time. It must be responsive, maneuverable, and easy to get in and out of.

That's why thousands of hardworking Cushman Police Vehicles are currently in use across the nation. Police Vehicles are a natural for sufficiently mobilizing the patrolman, marking tires, transporting emergency and or just providing weatherproof comfort for traffic control officers.

The tight 17-foot (5.2m) clearance circle and narrow 48" (1219mm) width allow the Police Vehicle-mounted officer to park and go places conventional vehicles could never go. It easily maneuvers in cramped quarters or congested traffic.

And the 18-hp air-cooled OMC engine is specially designed to handle a full day of demanding stop-and-go driving on regular gas.

There's a big 16-cubic-foot (0.45m(3)) cargo box for carrying traffic cones, warning signs or other law enforcement or first aid equipment. The power-assisted, lockable steel lid provides easy access to all enclosed contents. And there is additional open storage space between the box and the cab.

Even when the weather is bad, the Police Vehicle is ready. It has a big 15" (381 mm) wiper, an optional heater/defroster and optional cloth or lockable steel doors to provide operator visibility and comfort, even in cold climates.

The Police Vehicle comes in Police blue and white. For municipal, military or private security patrol, the Cushman Police Vehicle is the proven productivity booster. It makes the most of every manhour on any force.

(Graphics omitted) SPECIFICATIONS/MODEL 434 POLICE VEHICLE

STANDARD EQUIPMENT/DIMENSIONS/ACCESSORIES/MODIFICATIONS (Illegible Text)

** NOTE: This vehicle complies with U.S. Dept. of Transportation Motor Vehicle Safety Standards applicable to motorcycles. Operators should wear helmets which meet Motor Vehicle Safety Standard 218 and are marked with symbol "DOT" Certain states laws require wearing of helmets and special license for motorcycle operators.

Drawbar Pull

(Level Ground Maximum Speed 39 MPH) 4.2:1 Axle Ratio Speed Drawbar Speed Drawbar Engine MPH Lbs. km/h kg RPM 1st 1st 1st 1st 2000 39 430 143 195 2400 107 490 172 222 2800 124 425 200 193 3200 142 400 229 181 3600 160 360 257 163

(Maximum Speed 29 MPH) 6.5:1 Axle Ratio Speed Drawbar Speed Drawbar Engine MPH Lbs. km/h kg RPM 1st 1st 1st 1st 2000 54 500 103 272 2400 77 615 124 279 2800 89 595 143 270 3200 102 560 164 254 3600 115 500 185 227

Gradeability ** Gross Gross 4.2:1Axle 6.5 to 1 Axle Weight Weight Gradeability % Gradeability % Lbs. kg 1st 2nd 3rd 1st 2nd 3rd 1200 544 39 23 14 50 33 20 1300 590 36 21 13 50 30 18 1400 635 33 19 12 49 28 17 1500 680 31 18 11 46 26 16 1600 726 29 17 10 42 24 15 1700 771 27 16 10 40 23 14 1800 616 25 15 9 37 21 13 1900 562 24 14 9 35 20 12 2000 907 23 13 8 33 19 11 2100 953 22 12 8 31 18 10 2200 998 20 11 7 29 17 9

* Gross vehicle weight equals weight of the vehicle, plus operator, plus payload.

** Calculated equivalent based on available power efficiency and axle ratio.

(Graphics omitted)

THE E-Z-GO GX-800. THE LASTING IMPRESSION IT LEAVES WON'T BE ON YOUR TURF.

E-Z-GO introduces a new concept in landscape maintenance. The light-turf vehicle that's perfect when you need a utility car, and a truck is too much.

It's as strong as an ox, but gentle as a lamb.

The E-Z-GO GX-800 is the perfect utility vehicle for landscaping. It's light and gentle on your valuable grounds. Yet it's strong enough to carry loads, climb hills, and ride in bad weather. The body is constructed of Galvanneal, steel plating that's treated with rust preventive zinc Oxide. So they drive the fairway longer than any other utility vehicle. The chassis is welded high-yield tubular steel. It features a protective vinyl bumper strip, and a four-way diamond pattern treadplate design on the bed makes the GX-800 stronger all around. (Loadbed is not Galvannealed).

Put all your garden tools to bed.

The GX-800 has a 44" x 40" x 8" loadbed in the back that's deep enough to carry all your turf tools. It carries up to 800 lbs., and heavy duty springs and shocks make the ride smooth and comfortable, no matter how tough the rough. The loadbed tilts for complete access to drive package. And the sides and tailgate are easily removed.

This beast is a beauty on your budget.

You can afford three GX-800 vehicles for the price of one heavy-duty pickup truck. It's light enough so that it's economical on fuel and requires only standard maintenance. And it'll last years and years because it's engineered by E-Z-GO.

The GX-800 is suited for anything.

From the electronic ignition, to the dual rear brake, to the hypoid ring and pinion differential, the E-Z-GO GX-800 light turf vehicle is strong enough for any landscaping job. Yet it is light enough so it won't be a landscraper. It's perfect for golf courses, cemeteries, public parks, office grounds-keeping, or large, private residential landscaping.

The GX-800 is especially a utility runabout. It's a tremendous timesaver for the superintendant who has to get around the grounds to oversee his crew. It can take the shortest route to its destination. For more information, call your nearest E-Z-GO representative.

E-Z-GO GX-800 LIGHT TURF VEHICLE.

CHASSIS/POWERTRAIN SPECIFICATIONS.

Engine: 2 cycle, 244CC single cylinder air cooled, oil injected with electronic ignition. Drive Train/Transmission: Variable speed, fully automatic, forward and reverse. Torque Converter: Automatic, variable speed, dry type. Differential: Hypoid ring and pinion, 12.25 to 1 ratio.

Brakes: Mechanical, drum type, dual rear wheel brakes with over 47 square inches swept area. Foot operated parking brake with automatic release. Electrical System: External starter/generator, 12 volt negative ground system, with forward and reverse starting. Speed: Governed at 12 MPH, adjustable. Air Cleaner: Dry, replaceable cartridge. Carburetor: Fixed jet, float bowl with separate fuel pump. Suspension: Front: Heavy duty leaf springs with shocks. Rear: Heavy duty coil springs with heavy duty shocks. Steering: Rack and pinion. Fuel System: 6 gallon capacity. DIMENSIONAL SPECIFICATIONS. Weight: 810 lbs, dry. Fuel capacity 42 lbs. Length: 106 inches. Width: 48 inches (at rear wheels). Height: 47 inches (at steering wheel). Floor Height: 11 inches. Load Bed Height: 24 inches. Ground Clearance: 5 inches (at differential). Seat Height: 29 inches. Wheel Base: 71 inches. Front Tread Centers: 32-1/2 inches.

Rear Tread Centers: 39 inches. Turning Clearance Diameter: 23 feet Tires: 18 X 8:50 X 8 Softrac. Load Capacity: 800 lbs. (including operator and passenger). Load Bed Size: 44 inches wide, 40 inches long, 8 inches deep. Capacity: 8 cubic feet. FEATURES AND OPTIONS. Features: 1. Load Bed: Tilts for complete access to drive package. Removeable sides and tailgate. 2. Chassis: Welded high yield tubular steel. 3. Body: Galvanneal body and heavy duty four-way diamond pattern treadplate truck bed. 4. Body Protection: Wrap-around vinyl bumper/rub strip, chrome front bumper, and flexible rear fenders. 5. Battery: Delco Freedom II, maintenance free. 6. Safety: Key switch and electric horn. OPTIONS: Lighting Package Chrome Hubcaps Hour Meter Turn Signals Specifications subject to change without notice.