1983-2.20 | NHTSA

TYPE: INTERPRETATION-NHTSA

DATE: 06/23/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Middletown Van Pool Association

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your note of May 27, 1983, attaching correspondence between yourself and a District Manager for Ford Motor Company. You requested that we investigate the Ford E-150 van (which you state is a 15-passenger van) to determine if the stated Gross Vehicle Weight Rating of that vehicle is accurate.

Each manufacturer of a motor vehicle is required by the agency's regulations to place a certification label on the vehicle specifying that the vehicle is in compliance with all Federal motor vehicle safety standards and regulations (issued pursuant to the National Traffic and Motor Vehicle Safety Act of 1966). This certification label must include information regarding the vehicle's Gross Vehicle Weight Rating, as specified in 49 CFR 567.4(g)(3):

"(3) "Gross Vehicle Weight Rating" or "GVWR", followed by the appropriate value in pounds, which shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity. However, for school buses the minimum occupant weight allowance shall be 120 pounds."

Thus, you are correct in your assumption that the GVWR for a 15-passenger vehicle would have to include 2,250 pounds for occupant weight. Further, if a 15-passenger vehicle has a stated GVWR of 6,200 pounds, its unloaded vehicle weight could not exceed 3,950 pounds. I cannot state whether the Ford E-150 van has an unloaded vehicle weight in excess of this figure. However, I am sending a copy of your correspondence to our Office of Enforcement so that they may review this matter.

SINCERELY,

Marriott Hotels

5/27/83

MR. FRANK (Illegible Word) CHIEF COUNSEL NHTSA

THE ATTACHED FILE I BELIEVE POINTS TO A PROBLEM FORD MOTOR CO. HAS AND THEY NEED TO TAKE CORRECTIVE ACTION ON.

THANKS FOR LOOKING INTO THIS PROBLEM.

(Illegible Words) May 21, 1983

Mr. J. R. Rose - District Manager Ford Motor Company

Dear Mr. Rose

Just a note to let you know that I received your May 17 letter which contains various specific accuations that "you (refering to the writer) apparently intensified the problem of load by actually carrying an overload". Sorry to inform you Mr. Rose, but you are totally misinformed and there is some question on the facts you put forth. Consider:

1. A Ford representative, Mr. Frank Palbo, speced out the Van in question. . . .as per the attached specification sheet. He had very simple guidelines.

(a) Want a 15 passenger Ford Van

(b) Want to carry 10 passenger in Captains Chairs

2. Frank's note of August 17, 1981 and vehicle layout (copy attached) indicate,

(a) Seats will fit

(b) Van converter will do the job

3. Consider Mr. Rose, I specified a 15 Passanger Ford Van. . . .which normally contains:

(a) Two front seats . . . . equals 2

b) Three bench seats holding three persons each . . . equals 9

(d) If my math holds up . . . that is 2 + 9 + 4 = 15 people

(e) If your letter is correct, I quote "10 passengers possibly totally 1500 lbs" is correct . . . then your Ford 15 passenger van carries a payload of 15 times 150lbs = 2250 pounds of payload.

(f) Since we are saving 5 passengers we should be saving . . . . 5 times 150lbs = 750 pounds.

(g) Now, we added 8 captains chairs on bases verses your 4 bench seats . . . and since our seats our top quality, we'll agree they probably weigh on a two for one bases, 50 pounds each more than seats . . . so eights seats times 50lbs. = 400 pounds.

(h) O.K. - I saved 750lbs. by carrying 5 less passengers - I added 400lbs by using Captains Chairs . . . so basic subtraction says 750 minus 400 equals 350 pounds.

(i) Now the Van converter recommended we beef-up your flooring along with insulating the floor so we added 3/4" plywood to the floor in under your luxurious carpeting. Say that added 100lbs. to the Van. Let's see, I still have 350lbs. I saved and I take away 100lbs. from that and I have 250lbs. . net savings.

(j) We also added reading lights, electrical wire, front wood console, rear tire carrier . . . must all total out to at least 50lbs . . . . so I reduce my 250pounds savings by 50 and my new net savings is 200 pounds.

(k) Now our regular riders are of hearty stock and probably average 20lbs. overweight to your 150lbs. standard . . . so 10 passengers being 201lbs. each overweight equals 200lbs . . . can you believe it . . . 200 plus and 200 minus and I come out to . . . ZERO.

Now that we've finished our basic math quiz we can get down to the heart of the problem. Ford is selling a Cargo/Passenger vehicle that can't possibly meet their stated weights . . . . once again simple math says: GVW is 6200 pounds 15 Passengers -2250 pounds NVW is 3950 pounds

There is no way that vehicle or any Ford Vehicle setting on your showroom floor, equipped with bench seats and ready accept 15 passengers can weigh less than 400 pounds.

So, by your own figures, you show that you are falsely representing your product, that you are endangering peoples lives and worst of all you don't give a damn. And to prove that statement, I'll take a Saturday and in your facility, take out the eight captains chairs and bases and let you weigh the Van. And so that everyone knows things are on the up and up, let's invite the President of Ford to be the official weighing judge. He certainly has a vested interest. And just in case you don't want to accept the challenge, rest assured I'll do it on my own, having everything (Illegible Word) so that TV Stations, Consumer Organizations, FTC, and NHTSA can all benefit from this information.

So, back to you Mr. Rose and this time please do your homework and get the facts straight before you respond. I want to know why a Ford Motor Company representative speced and sold our group a Van that could not possibly conform to what we requested.

A VERY UNHAPPY FORD VAN LEASEE:

WILLIAM E. MEITER Middletown Van Pool Association

Ford Motor Company

May 17, 1983

William E. Meiter Middletown Van Pool Association

Dear Mr. Meiter:

This is in response to your recent letter to Mr. Peck in which you relate the problems experienced with replacement of brake linings and pads on your 1982 Ford E-150 Van.

While the warranty which you received with the Ford E-150 Van covers defects in material and workmanship within the first 12 months or 12,000 miles, it does not cover replacement of normal maintenance items such as brake linings (friction material). There are several factors that may effect brake life; for example: individual driving habits, road conditions, stop and go traffic into and within Manhattan and optional equipment such as 10 captian chairs causing extra load. You apparently intensified the problem of load by actually carrying an overload which is indicated in the following: Your vehicle's GVW is - 6,200 lbs. After alterations, your vehicle's net weight registered as - 5,720 ibs. Allowing you - 480 lbs. to use as load; i.e.: passengers.

By transporting 10 passengers possibly totalling 1,500 lbs., you are overloading your vehicle by approximately 1,000 lbs.

We regret that our response could not be more favorable, but appreciate having had the opportunity to review this matter for you.

J. R. Rose District Manager New York District

MANHATTAN FORD, LINCOLN-MERCURY, INC. (Illegible Words) 555 WEST 57th STREET, NEW YORK, N.Y. 10019 (201)581-7860

PRICE BOOK DATE PAGE DATE SALESMAN: SALBO

CUSTOMER: J.C. PENNY

ADDRESS

ATTENTION: W.E. MEITER 60 WALLACE ROAD, MIDDLETOWN, N.J. 07748 PHONE: 212-957-0092. MODEL: EIEO WINDOW VAN SUPER (Illeg.) 6941.- PAYLOAD PACKAGE: #2 GVM: 6200 N/C ENGINE: 302-V8 101.- TRANSMISSION: AUTOMATIC 352.- AXLES FRONT: (TRACTION LOK) REAR RATIO: 4.75 170.- TIRES: P235 75R 15XL STD.- SPARE TIRE: P235 75R 15XL 111.- AIR CONDITION DASH [] HI CAPACITY [] 1020.- ALTERNATOR: 60 AMP INCL W/AIR. - BATTERY: HD 36.- BRAKES: POWER STD BUMPER: REAR STEP. 84.- OUT CONVENIENCE GROUP: INTER WIPERS-12" O/N MIRROR-RHVANITY MIRROR 50.- COOLING SYS EXTRA [] SUPER [] 55.- DOOR SIDE: SLIDING OR HINGED N/C FUEL TANK: AUX. TOTAL CAP. 40 GALS 112.- (Illeg.) SPEED CONTROL 135.- GLASS (Illeg.): SWING OUT REAR. 40.- GLASS TINTED [] PRIVACY [] 264.- (Illeg.): COMFORT RIDE 15.- HEATER AUX [] HI OUTPUT [] 25.- INSULATION: DELUX 362.- LIGHT (Illeg.): COURTESY SWITCHES 24- LOCK GROUP: SECURITY 51.- MIRRORS: WESTERN LOW MTG. 69.- PAINT: ONE COLOR N/C PROTECTION GROUP RADIO: AM. FM. CASSETTE (4 SPEAKERS.) 224.- SEATING: QUAD CAPTS. CHAIRS. (2 ONLY) 1100.- 550 SHOCKS: HD FRONT & REAR (Illeg.) SPRING FRONT: HD REAR: HD 62.- STABILIZER BAR: FRONT 25.- STEERING: POWER 197.- (Illeg.): OUTSIDE SWING AWAY TIRE CARRIER. 117.- (Illeg.): CIGAR LIGHTER. 17.- FREIGHT 509.- DELIVERY & PREPARATION CHARGE 75.- 1981 PRICE (Illeg.) 82 ESTIMATED INCREASE 4% 500.- 12926- BILL, THE VAN PEOPLE ON LONG ISLAND WANT X 355.00- EACH INSTALLED FOR CAPTAINS CHAIRS FIGURING ANOTHER SEVEN TX 368.00-297.50 25.00- 2.972 I STILL WANT TO SHOP THIS ITEM LIGHTS 34.35 15 TOTAL 212.45 504.00 15.286

(Illegible Words)

P.S. ALL ACCESSORIES ARE FIGURED AT COST SO ANYTHING YOU THINK YOU DON'T WANT JUST DELETE.

LENNIE (Illegible Words) - 914-638-2972 3 YR. #562 MO PLUS INSURANCE. DOWN #600 + ONE MOS. PAYMENT $ 8,500 BUY BACK

MANHATTAN FORD, LINCOLN-MERCURY, INC

8-17-81

BILL,

JUST A QUICK NOTE TO TELL YOU THE FINANCE CO. APPROVED THE LEASE.

ALSO ATTACHED IS A LAY OUT. I GOT THE SEAT PEOPLE TO DROP THEIR PRICE TO $ 297.50 AND THE READING LIGHTS INSTALLED EACH SEAT $ 34.95 EACH.

I THINK WE HAVE EVERYTHING, GIVE ME A CALL AS SOON AS POSSIBLE

Frank

THIS IS THE SEAT MOVES BACK & FORWARD & SWIVELS DOES NOT RECLINE.

MAIN CUT OFF SWITCH FOR LIGHTS INSTLD. IN DASH

8 (Illegible Word) SEATS INSTLD ON SWIVEL BASES W/SLIDE TRACKS AS SHOWN

SEAT INSTALLATION NOTE:

POSITION ALL SEATS APPROXIMATELY 4 (Illegible Word) FROM SIDE TO ALLOW FOR:

- SWIVEL OF SEATS

- STOREAGE OF BLUE CASES ON FLOOR BETWEEN SEAT AND SIDE WALL

WE WILL USE 8 OF THESE DRIVE & PASSENGER WILL BE FORD.

SPECIAL NOTE:

CENTER THIS SEAT (MOVE INTO AISLE) SO PASSENGERS CAN ENTER BEHIND SEAT AND (Illegible Words) AISLE TO THEIR SEATS

9 SINGLE AIRCRAFT LIGHT W/SEPARATE SWITCHES INSTLD OVER EACH SEAT AS SHOWN.

(Graphics omitted)

Interpretation ID: 1983-2.20