Interpretation ID: nht91-5.47

DATE: September 12, 1991

FROM: Robert A. Adams -- Vice President, Solar Car Corporation

TO: Administrator -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10-21-91 from Paul Jackson Rice to Robert A. Adams (A38; Part 555; Part 555.6(c))

TEXT:

Solar Car Corporation is a small corporation located at 1300 Lake Washington Road, Melbourne, Florida 32935, and chartered under the laws of the State of Florida. The company retrofits standard gasoline powered vehicles to electric and solar electric configuration for short range use by individuals and fleet operators. Information on the company and photos of our vehicles are herewith enclosed. Safety features inherent in the frame and body of the vehicle are maintained without alteration.

We hope to retrofit about 100 vehicles during the next twelve months, including Ford Festivas, Dodge Colts and Chevy S 10 pickup trucks. Not more than 2,500 exempted vehicles will be sold in the United States in any 12 month period for which an exemption may be granted pursuant to paragraph (C)(5) of 555.6 of the Code. It is the intention of Solar Car Corporation to conform with the safety standards of the Code at the end of the exemption period.

Solar Car Corporation hereby respectfully petitions the NHTSA for a temporary exemption for three years from federal motor vehicle safety standards as defined in Part 555 of the Code of Federal Regulations, Section 49 - Transportation on the basis of low emission engine features.

Electric and solar electric vehicles are inherently free from polluting emissions. A typical solar electric retrofit by Solar Car Corporation of a Ford Festiva has been subjected to substantial engineering tests at the California Air Resources Board facility in El Monte, California. Results of those tests and the judgement of CARB relative to the safety of the vehicle should be available to you from CARB.

Granting of an exemption would be in the public interest for several reasons, including current and proposed legislation (brief summary attached) either requiring or encouraging the use of low and zero emission vehicles, the environmental and health needs to reduce or eliminate pollution, and the need to reduce dependence on overseas sources of a rapidly depleting world supply of petroleum.

Granting of an exemption would also be consistent with the objectives of the National Traffic and Motor Vehicle Safety Act as these non internal combustion powered vehicles are inherently safer than those traditionally using gasoline. I, in my lifetime, have, on three separate occasions, witnessed automobile accidents in which an ill fated driver is seen sitting in his car, engulfed in gasoline flames, with bystanders helpless to rescue him.

Our electric vehicles differ from a conventional gasoline powered vehicle in that an Advanced D.C. Motors, Inc. electric motor (description enclosed herewith) replaces the standard internal combustion engine and is coupled to the standard transmission by means of a heavy cast aluminum adapter plate. A Curtis electronic controller controls the electricity between the motor and batteries. We currently use ten batteries, most of which are secured in a heavy duty fiberglass container in the rear portion of the vehicle.

Solar Car Corporation has reason to believe that a temporary exemption will facilitate the development and field evaluation of its electric and solar electric vehicles. Several municipal and utility company fleet managers have serious interest in acquiring our vehicles for demonstration and field testing, and the Arizona Public Service Company has placed an order with us. The Energy Office of the State of Arizona has encouraged us over the past two years to produce and sell these vehicles in Arizona, and, as a matter of record, the Governor of Arizona rode in one of our prototype solar electric cars during the dedication ceremonies for the completion of the final segment of Interstate 10 which runs from Florida to California. We are an accredited vendor for the State of Arizona which will be purchasing fleets of electric vehicles during the next 12 months, subject to the exemption petitioned hereby. In addition to Arizona, municipal and utility fleet operators in California, Nevada, and Connecticut have expressed interest in our supplying purchase proposals that will allow them to further comply with mandates and incentives relative to the implementation of electric and solar electric vehicles as additions to their fleets.

I trust that the above information will allow you to make a favorable judgement in granting to Solar Car Corporation its request for a temporary exemption from federal motor vehicle safety standards on the basis of low emission engine features.