Interpretation ID: aiam2788
Hess and Eisenhardt
Co.
Blue Ash Avenue
Cincinnati
OH 45242;
Dear Mr. Miller: This responds to your recent letter requesting an interpretatio concerning the vehicle classification of a proposed new station wagon having a Cadillac commercial chassis. Specifically, you ask whether the vehicle can be classified as a multipurpose passenger vehicle on the basis that it has the same chassis that is used on hearses and ambulances, which are multipurpose passenger vehicles.; Based on your description, it is the agency's opinion that the propose new station wagon would be classified as a passenger car. A multipurpose passenger vehicle is described in 49 CFR S 571.3 as 'a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on truck chassis or with special features for occasional off-road operation.' The vehicle you described does not meet either of the criteria of that definition. The fact that your vehicle would be built on the same chassis as hearses and ambulances does not affect its classification as a passenger car.; The classification of hearses and ambulances as multipurpose passenge vehicles was based upon specific policy considerations. The unique functions of these vehicles are accommodated by a strengthening of their chassis. Because of the special uses to which they are put, other aspects of the vehicles are designed in a manner which inhibits compliance with several passenger car standards. Given the chassis modifications and the special uses of these vehicles, the NHTSA determined that the policy considerations that led to the placing of vehicles with truck chassis into a category separate from passenger cars apply equally to ambulances and hearses, and that the chassis used for these vehicles may reasonably be considered truck chassis for purposes of classification. These policy considerations are not relevant to the vehicle you describe since it is apparently designed to function primarily as a passenger-carrying vehicle.; Sincerely, Joseph J. Levin, Jr., Chief Counsel