Interpretation ID: nht92-5.48

DATE: June 23, 1992

FROM: R. Marie McFadden -- Cable Car Concept, Inc.

TO: Paul Jackson Rice

TITLE: None

ATTACHMT: Attached to letter dated 8/20/92 from Paul J. Rice to R. Marie McFadden (A39; Std. 207; Std. 208)

TEXT:

We are a manufacturer of rubber tired trolleys, Road-Trains and Trolley-Trams. These vehicles can be used on the highway and are motorized, licensed vehicles. I have enclosed some spec sheets to give you an idea of what we build.

We would like a letter of interpretation on the following:

1 - Our small unit has a GVW of 12,300, we understand that we need seat belts for the driver only, this small unit is an eighteen passenger. Our largest is a thirty-two passenger unit with a GVW of 17,000 lbs.

2 - As you can see on our Tram specs we do have oak seats, is there a ruling on this at all.

3 - We have one seat on some of our vehicles that we refer to as a jump seat it is located in front of the entrance door, this seats two people and faces the driver. Would the same ruling apply to this seat as for the other passenger seats.

We have been manufacturing Trolleys for over twenty years, and are aware that new regulations came into effect Sept 1, 1991. We also have a copy of Federal Regulation #208. We would appreciate if you could interpretate the ruling before this date and after.

We appreciate your time, and await your reply.

Attachment

Brochure describes the Mini Trolly manufactured by Cable Car Concepts, Inc. (Text omitted)