Interpretation ID: nht91-5.41

DATE: September 9, 1991

FROM: Gary Starr -- Solar Electric Engineering

TO: NHTSA

TITLE: Re Petition for exemption on the basis for the facilitation of low-emission engine features

ATTACHMT: Attached to letter dated 10-23-91 from Paul Jackson Rice to Gary Starr (A38; Part 567; Part 555)

TEXT:

Applicant: Solar Electric Engineering, Inc.(a California Corporation) 116 Fourth Street Contact: Gary Starr Santa Rosa, CA 94010

Basis for petition:

1) The motor vehicle is a low-emission vehicle as defined by section 123(g) of the Act as the vehicle is an electric vehicle.

2) Since our vehicle is a standard vehicle manufactured under NHTSA standards and originally certified by the O.E.M., the vehicle should still meet most of the original standards.

i) The motor vehicle equipped with the low emission engine (an electric motor) would if exempt perhaps differ with standard 103 (Windshield Defrosting), standard 208, specifically part 572 (Anthropomorphic Test Dummy), standard 105 (Hydraulic brake systems, and perhaps other standards which are unknown at this time or would not apply to an electric vehicle.

ii, iii, iv) The vehicles are "converted" or "altered" conventional vehicles; according to one NHTSA safety engineer, the NHTSA may not require the exemption application; however, "to be safe", we are submitting one, while we are undergoing in-house and third party testing of the vehicle. 3) A temporary exemption would greatly facilitate both the development and field evaluation of the vehicle since some of our pending financing and actual purchase orders have insisted that we apply for the exemption.

4) At the end of the exemption period, we intend to conform with all standards.

5) Not more than 2500 exempted vehicles will be sold in the United States in any 12 month period for which an exemption may be granted.

6) No data need be withheld at this time.

7) It is in the public interest and consistent with the objectives of the National Safety Act to grant the exemption because clean air vehicles are of vital interest to the public and no known safety acts would be exempted to the point to put the public at any unacceptable safety risk.