Interpretation ID: nht89-2.90

TYPE: INTERPRETATION-NHTSA

DATE: 08/31/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: BRADLEY J. BAKER -- PRESIDENT CLASSIC MANUFACTURING, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 10/21/88 FROM BRADLEY J. BAKER -- CLASSIC MANUFACTURING TO TAYLOR VINSON -- NHTSA; OCC 2717

TEXT: Dear Mr. Baker:

This is in reply to your letter to Taylor Vinson of this Office, with reference to a product your company manufactures, a "car dolly used to tow a vehicle behind motor homes." You question whether the dolly is a motor vehicle, and if so, whether identifi cation lamps are necessary for it. I regret the delay in responding.

The car dolly appears to be a vehicle drawn by mechanical power manufactured primarily for use on the public roads, and thus a "motor vehicle" subject to the jurisdiction of this agency. Specifically, it would be a "trailer", since it is a motor vehicle without motive power, designed for carrying property and for being drawn by another motor vehicle. Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, requires identification lamps on all trailers whose o verall width is 80 inches or more. Therefore, if the overall width of your dolly is less than 80 inches, it need not be equipped with identification lamps.

Sincerely,