Interpretation ID: nht88-3.59

TYPE: INTERPRETATION-NHTSA

DATE: SEPTEMBER 27, 1988

FROM: CLARK, TRACY L. JR. -- COTTLE INDUSTRIES VICE PRESIDENT

TO: ERICA JONES -- CHIEF COUNSEL-NHTSA

TITLE: NONE

ATTACHMT: DECEMBER 19, 1988 LETTER FROM JONES TO CLARK

TEXT: We are finalizing arrangements to produce a three-wheeled gasoline-powered vehicle. The vehicle will be classified as either a moped or a motorcycle depending on choice of engine size.

In reviewing sections 566-568 of the Federal Motor Vehicle Safety Standards and Regulations, it appeared that we should be classified as an alterer. I wanted to confirm this, so I contacted your organization directly. I discussed our classification by phone with Ms. Dorothy Nakoma of your offices. She believes that we should indeed be registered as an 'alterer of a certified vehicle'. She also suggested that we write to you and get a written opinion confirming the correct classification.

I have enclosed a brochure which highlights the basic description of the vehicle. The production process goes as follows:

1) We purchase a completed, certified Honda moped.

2) We then remove the plastic body shell and seating components.

3) Next, the frame is cut behind the steering column, separating the Honda vehicle into two sections.

4) The front section is welded to the tubular steel frame.

5) The rear section is welded to the tubular steel frame.

6) A third wheel assembly added to the frame.

7) Wiring is completed and the fiberglass body shell is installed.

The Honda front end and drive train components continue to retain their integrity.

We intend to issue a new Certificate of origin for each vehicle, but would continue to use Honda's VIN number as identification. Please confirm this procedure.

Several states make no provision for classifying alterers. Their categories are limited to manufacturers and franchised dealers or distributors. We will register as a manufacturer in these states.

If you have any questions, or require further information, please do not hesitate to contact me. Thank you for your time and consideration on this issue. We look forward to your response.

Now There Is Alternative Transportation For Disabled Individuals -- For Use On Public Roads

Introducing the Chariot

The CHARIOT is a three-wheeled vehicle unlike any other type of mobility vehicle available today. Designed for use on public roads, the CHARIOT provides safe, reliable, and self-sufficient transportation for disabled individuals -- at an affordable pric e.

Now You Can Easily Go Shopping, Visiting, or Sight-Seeing

Whether your trip is for business, pleasure, or adventure, the CHARIOT is the most enjoyable way to travel. With its reliable Honda engine, you can attain speeds of as much as 25 miles per hour. A three-mile trip in a power wheelchair can take up to an hour. In the CHARIOT, you can cover the same distance in just eight minutes.

Ease Of Use For Increased Self-Sufficiency

The CHARIOT's hand-operated controls, automatic transmission, lighted speedometer, electric fuel gauge, oil warning light, direction signals, and convenient gas tank make it a snap to use and maintain.

Individuals with normal upper-body abilities can use the CHARIOT. All you do is drive your wheelchair in from the back, fasten it in place, close the tailgate, turn the ignition key, and you're on your way.

For Business Or Pleasure -- A Safe Way To Travel

The CHARIOT has built-in safety features to ensure your ride is comfortable and safe:

* a low center of gravity and three wheels provide stability and balance

* a welded steel chassis and safety frame absorb shock and provide superior protection

* a patented safety lock holds your wheelchair in place

* a powerful headlight increases your visibility

* anti-vibration rear suspension gives a quieter ride

* front and rear independent brakes create smoother stopping

No Special Permits Needed

The CHARIOT is designed for use on public roads and is subject to the rules and regulations governing motor vehicles. It is licensed like a moped. All you need is a regular driver's license -- no special application forms or permits are needed.

A Full One-Year Warranty.

Your CHARIOT is covered by a full one-year or 2,500 mile warranty on all parts and labor. If anything should go wrong with your CHARIOT while it is under warranty, we'll fix it for free. Ask your dealer or refer to the vehicle warranty for specific cov erage.

Factory-Trained Dealers

The CHARIOT is distributed through a network of dealers trained by Cottle Industries.

Our dealers help you learn how to operate your CHARIOT and provide you with the courteous after-sales and repair service you deserve.

If you ever need any help with your vehicle, just call. We'll be there to help. If it's necessary, we'll even send a representative to see you in person to make sure your problem is solved quickly and to your satisfaction.

Independence At An Affordable Price

The CHARIOT gives you the independence to do what you want to do, when you want to do it, at a price you can afford. There's no other vehicle like it available today.

The basic price is just $ 4,800. Compare this to price tags on specially equipped vans, which often require assistance to use and a lot of money to maintain. And when you compare the CHARIOT's speed and freedom of mobility with traditional motorized wh eel-chairs, you'll find there's really no comparison.

Get Around In Style

Classy and attractive, the CHARIOT gives you the thrill and exhilaration of motorcyling -- but with much greater stability and safety. You go places where a regular wheelchair can't. And you go in style.

"There are quite a number of handicapped people that would love to know and own a vehicle such as the CHARIOT; so we can feel the sun on our shoulders and the wind at our backs, rather than being stuck in a stuffy, hot car or being pushed around in our w heelchairs." -- Martin Speller, Bridgeport, Connecticut

Now Available In The United States

The CHARIOT was originally developed under the name Nippi by Special Vehicle Designs, Ltd. of Leicestershire, England. Over 400 vehicles have been sold in England since 1986 to help disabled individuals lead a more fulfilling life.

Today, through a special agreement with Special Vehicle Designs, Cottle Industries, Inc., has the exclusive rights to manufacture and market the CHARIOT in the U.S. and Canada.

The CHARIOT/Mobility Vehicle At A Glance

* Welded steel safety chassis * Safety locks

* Gasoline-powered

* 70 miles per gallon

* One gallon gas tank

* Three wheels

* Dimensions: 72" long, 52" wide, 40" high

* Total weight: 270 pounds

* 49 cc two-stroke engine

* Electric ignition

* Automatic transmission

* Steel wheels

* 2.75 x 10-inch tires

* Independent suspension with hydraulic damper

* 12-volt battery

Options for the CHARIOT

* wind screen

* custom colors

* 80 cc engine (licensed as a motorcycle, speeds of up to 45 m.p.h.)

About Cottle Industries

Cottle Industries, Inc., researches, develops, manufacturers, and markets devices that help disabled people lead more productive, independent, and fulfilling lives. Our product line includes the CHARIOT and other fourth-generation mobility vehicles that overcome many of the limitations of conventional wheelchairs.

We are committed to excellence. To this end, we conduct extensive research to apply technological innovations to our products. We offer a complete sales and after-sales support service to ensure customer satisfaction. All complaints are handled direct ly by us, not by our dealers. This direct approach makes for better quality control and service.

Cottle Industries, Inc. P.O. Box 1165 Fairfield, Iowa 52556

Call Your Local Dealer Today To find out more about the CHARIOT, call your local dealer today or phone Cottle Industries at 515/472-7281 directly for the name of the dealer closest to you.

Cottle Industries recommends wearing a safety helmet when operating the CHARIOT.