Interpretation ID: nht93-2.36

DATE: March 30, 1993

FROM: Arvind V. Rajan -- Vice President, Marketing and Planning, Solectria Corporation

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-26-93 from John Womack to Arvind V. Rajan (A41; Part 591)

TEXT: The Solectria Corporation is a manufacturer of electric vehicles and advanced EV components, based in Massachusetts. We currently produce the Solectria Force, which is a Geo Metro that has been converted to electric drive. In order to serve the needs of vehicle customers in Southeast Asia and the Caribbean, we need to use a vehicle chassis with right-hand steering. Since the Geo Metro is only available in left-hand steering we will need to import an equivalent vehicle, the Suzuki Swift, from Japan. After we receive the vehicle, we will convert it to electric, and immediately export it.

The Suzuki Swift with right-hand drive may not be certified for use in the United States by NHTSA. However, as the vehicles will never be used on public roads in the United States and will not be sold to U.S. customers, we believe that we will be allowed to import them into the U.S. Mr. Frank Turpin of NHTSA has confirmed this view. However, the U.S. Customs Office has informed us that it will need written confirmation from the Department of Transportation before releasing such vehicles to us.

We would appreciate written confirmation from the D.O.T. that we are indeed permitted to import such vehicles for the purposes mentioned above. If you have any questions, please call me at (508) 658-2231 or fax me at (508) 658-3224. Thank you for your time and attention, and we look forward to hearing from you.