Interpretation ID: nht92-3.6

DATE: 10/27/92

FROM: J. LESLIE DOBSON, OWNER, MCKINNEY VEHICLE SERVICES

TO: PAUL JACKSON RICE -- NATIONAL HIGHWAY SAFETY ADMINISTRATION

ATTACHMT: ATTACHED TO LETTER DATED 11-20-92 FROM PAUL J. RICE TO J. LESLIE DOBSON (A40; PART 567); ALSO ATTACHED TO 3-19-91 LETTER FROM PAUL RICE TO JERRY TASSAN (PART 567); ALSO ATTACHED TO 7-1-92 LETTER FROM PAUL RICE TO GENE FOUTS

TEXT: We are a small business engaged in the rental of trucks in Los Angeles, California. We have approximately 50 Bobtail trucks with a gross vehicle weight, ("GVW"), of 28,000 pounds each. Recently, the licensing laws in the State of California were changed to require a special class of driver's license for vehicles with a GVW in excess of 236,00 pounds. This has resulted in a dramatic decrese in our rental business, since many of our small customers do not possess such a license.

We believe that a reclassification of our Bobtail trucks to a GVW of less than 26,000 pounds would not adversely effect safety. The California driver's license requirement was intended to ensure that drivers of large commercial vehicles were specially trained. However, with Bobtail trucks, no special training is required for their safe operation. Indeed, over the last decade, we have had an excellent safety record with these vehicles. Our Bobtail trucks have only two axles and cannot carry large amounts of weight. They are traditionally used for local furniture delivery and for similar purposes. The boxes and flatbeds on our trucks are only 22 feet in length and they are incapable of towing a trailer.

Therefore, we would request your advice and assistance in how we would go about having these Bobtail trucks reclassified at 26,000 GVW. Would you be so kind as to contact me with some direction as to how we should proceed.

Thank you for your anticipated cooperation and assistance.