Mr. Mac M. Yousry

Managing Director

Global Vehicle Services Corp.

1892 North Main Street

Orange, CA 92865

Dear Mr. Yousry:

This responds to your letter asking whether the GV11, a motor vehicle designed to carry 10 persons or less, mounted on a truck chassis, and containing certain special features that enable off-road operation, qualifies as a multipurpose passenger vehicle (MPV) for purposes of the Federal Motor Vehicle Safety Standards (FMVSSs). Based upon the information supplied to this agency and for the reasons explained below, we would consider the GV11 to be an MPV under 49 CFR 571.3.

You have requested confidentiality of some information regarding the specifications of your vehicle, and we have granted that confidentiality. As the confidential information was not required to answer your question, we will not discuss it in this letter.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) places the responsibility for classifying a particular vehicle in the first instance on the vehicle manufacturer. For this reason, NHTSA does not approve or endorse any vehicle classifications before the manufacturer itself has classified a particular vehicle. We will, however, tentatively state how we believe the vehicle would be classified for the purposes of our safety standards.

The term multipurpose passenger vehicle is defined in 49 CFR 571.3 as a motor vehicle with motive power, except a low-speed vehicle or trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation. You state that the GV11 is designed to carry 10 persons or less, thus meeting the first part of the definition. You also state that the GV11 is mounted on a truck chassis, thus fulfilling the second part. Based upon this description, it appears to us that this vehicle could be classified as a multipurpose passenger vehicle.

We note that while your letter also described certain confidential features that you believe would enable off-road operation, it was not necessary to analyze those features to make our determination. Thus, we make no opinion in this letter as to whether those features would impact the classification of the GV11 under the FMVSS.

If you have any additional questions, contact Ari Scott of my staff at (202) 366-2992.


Anthony M. Cooke

Chief Counsel