68 Industrial Way
Wilmington, MA 01887
We have received your letter of December 8, 1994, with respect to the applicability of two Federal motor vehicle safety standards to electric vehicles.
With respect to Standard No. 301 Fuel System Integrity, you believe that the language of S3 implies that "it applies to all passenger vehicles, but to only those trucks with GVWR of 10,000 pounds or less and that use fuel with a boiling point above 32 degrees F." You conclude, however, that "this standard appears not to apply to electric vehicles with no liquid fuel."
Under S3 of Standard No. 301, the standard applies to certain specified vehicles that "use fuel with a boiling point above 32 degrees F". The use of the fuel is not stated. Obviously, electric vehicles do not use liquid fuel for propulsion, but some of them do use a small amount of liquid fuel in their heating systems. Standard No. 301 would apply to an electric vehicle with a fuel-fired heating system.
With respect to Standard No. 102 Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect, you ask for "a clarification of this standard with regard to single speed transmissions" and, if it is applicable, ask that S3.1.3 "be rewritten or interpreted to include the initial activation of EV motor controllers as well as engine starters."
NHTSA has previously concluded that electric vehicles with single speed transmissions are excluded from Standard No. 102 (58 FR at 4646). I enclose a copy of the Federal Register notice reflecting this conclusion.
Philip R. Recht Chief Counsel
Enclosure ref:102#301 d:2/2/95