ID: nht88-4.17

TYPE: INTERPRETATION-NHTSA

DATE: 11/26/88

FROM: M. M. YOON -- DIRECTOR, IN-ONE DEVELOPMENT CORP. SEOUL, KOREA

TO: STEVE KRATZTE -- OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/31/89 FROM ERIKA Z. JONES -- NHTSA TO M. J. YOON, REDBOOK A33 (2), PART 571.3

TEXT: DEAR, MR. KRATZTE

WE, IN-ONE DEVELOPMENT CORP., ARE DOING AS RESEARCH AND DEVELOPMENT CENTER OF SSANGYONG MOTOR COMPANY, PROCEEDING TWO PROJECTS WHICH ONE OFF-ROAD VEHICLE AND ONE PASSENGER CAR AND PLANNING TO LAUNCH THE CARS IN U.S.A.

THEREFORE, WE WOULD LIKE TO KNOW THE VEHICLE CLASSIFICATIONS (PASSENGER CAR OR MULTIPURPOSE PASSENGER CAR) OF OFF-ROAD VEHICLES PLANNED TO PRODUCT IN THE END OF 1991.

FOR YOUR REFERENCE, GENERAL SPECIFICATIONS OF THE VEHICLE ARE AS FOLLOWS.

OVERALL LENGTH: 4200 approx. 4250 mm, DRIVE SYSTEM: 4 WHEEL DRIVE (PART TIME)

OVERALL WIDTH: 1716 mm, FRAME: LADDER TYPE FRAME

HEIGHT (ON GROUND): 1670 approx. 1700 mm

WINDSCREEN SLOPE ANGLE: 55 degrees

APPROACH ANGLE: 40 degrees

DEPARTUER ANGLE: 30 degrees

GROUND CLEARANCE (IN LADEN CONDITION): MINIMUM 200 mm

(THE SHAPE OF THE VEHICLE LOOKS LIKE PASSENGER CAR; AERODYNAMIC SHAPE)

AND, WE ALSO WANT TO KNOW THE CRITERIA FOR VEHICLE TYPE CLASSIFICATIONS. YOU ARE KINDLY REQUESTED TO SENT THE INFORMATIONS, IF AVAILABLE. WE ARE LOOKING FORWARD TO YOUR PROMPT RESPONSE. NOTE). OUR ADDRESS & FAX. NO ARE AS FOLLOWS.

ADDRESS: 2nd FLOOR, GUKDONG BUILDING, 3-GA CHUNGMOO-RO, JUNG-GU, SEOUL, KOREA.

FAX. NO: 02-277-5321

SINCERELY YOURS

ID: nht88-4.18

TYPE: INTERPRETATION-NHTSA

DATE: NOVEMBER 28, 1988

FROM: GEORGE F. BALL -- GM OFFICE OF THE GENERAL COUNSEL

TO: ERIKA Z. JONES, -- CHIEF COUNSEL-NHTSA

TITLE: PART 571.3 VEHICLE CLASSIFICATION OF THE GM 200

ATTACHMT: DECEMBER 21, 1988 LETTER FROM JONES TO BALL

TEXT: On November 21, 1988, representatives of General Motors Corporation (GM) met with you and other NHTSA personnel to review GM's bases for classifying the passenger van versions of its GM 200 minivan family as multipurpose passenger vehicles (MPVs) under 4 9 C.F.R. Part 571.3. The purpose of this letter is to summarize that presentation and to seek your concurrence with our determination. You will recall that "GM 200" is the program designation for the entire minivan family, and that the cargo van version of that family will be classified as a truck under Part 571.3.

Pre-introduction publicity relating to this vehicle family has made reference to the GM 200 being launched from the GM "A" car platform. Although the GM 200 will share some of the "A" car front wheel drive components, the common chassis used in the carg o and passenger van versions of the GM 200 is unique from the "A" car chassis and its unique features make it more suitable for commercial usage than a passenger car chassis. In this regard, the GM 200 cargo van version and the passenger van with its re ar seats removed will have approximately 95 percent greater cargo-carrying volume than an "A" car station wagon.

With respect to pertinent definitions in the Federal Motor Vehicle Safety Standards and NHTSA interpretations, the definition of "multipurpose passenger vehicle" in Part 571.3 provides that an MPV is "a motor vehicle with motive power, except a 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." As we indicated during our meeting; the focus of our vehicle classification was based on the "truck chassis" alternative of the definition.

2

Although "truck chassis" is not defined in the regulations, the NHTSA indicated in the December 1, 1983 interpretation letter to Mazda that:

The "chassis" of a vehicle includes the vehicle's power train as well as its entire load structure. In the case of a vehicle using unibody construction, this load supporting structure would technically include the floor pan.

The fact that a common chassis is used in a family of vehicles, one member of which is classified as a "truck," is evidence that the common chassis is a "truck chassis." However, further evidence is needed to demonstrate that the chassis has truck att ributes, such as information showing the design to be more suitable for heavy duty, commercial operation than a passenger car chassis.

With these criteria in mind, GM concluded that the passenger van versions of the GM 200 minivan are appropriately classified as MPVs because the GM 200 minivan family is constructed on a "truck chassis." In this regard, "truck attributes" of the GM 200 c hassis which make it more suitable for commercial use than a passenger car chassis include:

1. An integrated ladder-type frame with full-length longitudinal rails and supporting cross-members;

2. An extended width rear axle;

3. A specific truck family powertrain certified to comply with light-duty truck emission standards, including the 11-year, 120,000 mile "useful life" requirements; and

4. A flat load floor.

As further evidence that the GM 200 chassis is a "truck chassis," a cargo van version will be marketed and sold by Chevrolet to compete in the commercial truck market. As we demonstrated during our presentation and through the review of a prototype of t he cargo van, this truck version of the GM 200 minivan family has commercial use characteristics not available in a passenger car.

3

We also showed at the November 21 meeting through an analysis performed by Failure Analysis Associates, that minivans classified as MPVs have certain similar chassis and body characteristics. In this connection, Failure Analysis Associates concluded fro m its review of the GM 200 and nine competitive MPVs that the GM 200 has a frame construction similar to these MPVs and falls within the range of chassis and body measurements exhibited by such competitive vehicles.

In summary, the passenger van versions of the GM 200 minivan family are constructed on a "truck chassis," and are, therefore, appropriately classified as "multipurpose passenger vehicles" pursuant to 49 C.F.R. Part 571.3, inasmuch as: (1) the GM 200 fami ly of vehicles uses a common chassis which has "truck attributes" which make it more suitable for commercial use than a passenger car chassis; (2) a cargo van version will be produced to compete in the commercial truck market; and (3) the physical chassi s and body characteristics of the GM 200 fall within the range exhibited by competitive MPVs.

Due to the confidential and proprietary nature of the future product information and the product comparisons included in certain slides presented at the November 21 meeting and attached to this letter, GM requests that they be afforded confidential treat ment by the NHTSA and Department of Transportation until the GM 200 family of vehicles is made available for sale to the public.

Future product plans, descriptions and comparisons of future products with competitive vehicles are "trade secrets" within the meaning of Section 1905 of Title 18 of the United States Code, entitled to confidential treatment pursuant to Section 552(b)(4) of Title 5 of the United States Code (Exemption 4 of the Freedom of Information Act) and Section 112(e) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended and implemented in Part 512 of Title 49 of the Code of Federal Regulations.

The specific slides for which confidential treatment is being requested have been labeled "GM CONFIDENTIAL". The information contained in these slides is not customarily made public by GM. The disclosure to the public of GM's future product plans, desc riptions and comparisons with competitive vehicles is likely to result in significant competitive harm to GM. Furthermore, GM believes that this information falls within the "Class Determinations" in Appendix B to 49 C.F.R. Part 512 which the NHTSA has concluded would presumptively result in significant competitive damage to the submitter.

4

Pursuant to 49 C.F.R. Part 512.4(e), an affidavit in support of this assertion of confidentiality is also attached. If you should disagree with our position that these documents are entitled to confidential treatment, we would appreciate the opportunity to provide you with a further explanation and to address any concerns you may have.

We trust that the information contained in this letter and presented at the November 21 meeting will provide a sufficient basis for the NHTSA to concur with GM's determination regarding the vehicle classification of the GM 200. However, please contact m e if I can be of any further assistance to you in this matter.

Attachments

(Affidavit Omitted.)

ID: nht88-4.19

TYPE: INTERPRETATION-NHTSA

DATE: 11/28/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL

TO: ROBERT L. RIPLEY -- PRESIDENT KNAACK MANUFACTURING CO.

TITLE: NONE

ATTACHMT: LETTER DATED 08/11/88 TO ERIKA Z JONES FROM ROBERT L. RIPLEY OCC -- 2406

TEXT: Dear Mr. Ripley:

This is a response to your letter asking this agency to review three product catalogs you submitted with your letter, and tell you whether your company is required to furnish information pursuant to 49 CFR Part 566, Manufacturer Identification. Based on the information you supplied with your letter, your company is required to file information under Part 566 for the warning devices shown in one of the catalogs, but not for any of the other items shown in the three catalogs.

As specified in the Application section of Part 566 (@ 566.3), Part 566 applies to (1) all manufacturers of motor vehicles and (2) manufacturers of motor vehicle equipment, other than tires, to which a safety standard applies. The only item advertised i n the three catalogs that is motor vehicle equipment to which a safety standard applies is the "Safety Reflector Kit" shown on page 6 of the catalog entitled "weather guard For Full-Size and Mini Vans." These devices are subject to Standard 125, Warning Devices (49 CFR @ 571.125). Accordingly, your company, as the manufacturer of these devices, must furnish the information specified in @ 566.5 within the time period specified in @ 566.6.

I hope you find this information helpful. If you have further questions, please contact Joan F. Tilghman of my staff at (202) 366-2992.

Sincerely,

ID: nht88-4.2

TYPE: INTERPRETATION-NHTSA

DATE: 11/03/88

FROM: MELANIE TURNER -- QUALITY CONTROL DIAMOND STAR MOTORS

TO: ERICA Z. JONES -- CHIEF COUNCIL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/26/89 FROM STEPHEN P. WOOD -- NHTSA TO MELANIE TURNER; REDBOOK A33 [2]; STANDARD 205; LETTER DATED 08/31/84 FROM FRANK BERNDT -- NHTSA TO TOYOTA MOTOR CORPORATION; STANDARD 205; LETTER DATED 04/13/78 FROM JOSEPH J. L EVIN -- NHTSA TO MOE PARE; NOA 30; STANDARD 205

TEXT: Dear Ms. Jones,

Diamond Star Motors is presently producing cars for Chrysler and Mitsubishi. In order to insure that DSM is meeting FMVSS STD 205 (Glass Markings) without fail we'd like to request a written interpretation of this Standard for clarification purposes. P lease address the following questions:

1. Must the manufacturer markings be in a specified position on the glass (particularly side door glass?) If so, what are the specifications?

2. Must the manufacturing markings be readily and completely visible without dissassembly of the vehicle and without manually moving any molding in order to make markings more visible to the eye?

3. Must the markings be readily readable in a certain position? For example . . . from left to right, right to left, right-side up, or up side down?

4. Must the markings be readable from the outside of the car of the inside of the car?

5. What is the specification for the height of the lettering, point size, and dimensioning of the markings?

6. What does the content of these labels consist of?

Thank you for your cooperation. I greatly appreciate your assistance in supplying any additional information with reguards to this topic. I look forward to hearing from you as soon as possible. Your reply is critical to the quality of our cars.

Thank you,

ID: nht88-4.20

TYPE: INTERPRETATION-NHTSA

DATE: 11/29/88

FROM: JAMES A. COWAN -- DIRECTOR OF ENGINEERING CROWN COACH INC

TO: ERIKA JONES -- CHIEF COUNSEL U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: FMVSS 217 BUS WINDOW RETENTION AND RELEASE

ATTACHMT: ATTACHED TO LETTER DATED 01/09/90 FROM STEPHEN P. WOOD -- NHTSA TO JAMES A. COWAN -- CROWN COACH INC; REDBOOK A35; STANDARD 217; LETTER DATED 11/24/89 FROM JAMES A. COWAN -- CROWN COACH INC TO ERIKA JONES -- NHTSA; RE FMVSS 227, BUS WINDOW RETE NTION AND RELEASE; OCC 2847

TEXT: Dear Ms. Jones:

In a telephone conversation this morning with Marty J. Paliokes Safety Compliance Engineer for NHTSA, we were referred to your office for an interpretation regarding FMVSS 217, Bus Window Retention and Release. Our question regards figures 1 and 2 (p ages 418 and 419, CFR 49, Parts 400 to 999, October 1, 1985) of the subject regulation.

As background information, Crown Coach has developed a new transit style school bus based on our current production body shell. The current bus has been tested and certified for FMVSS 217 compliance as recently as March, 1988; see report no. 217-MSE- 87-10-TR7122-10 prepared under contract no. DTNH22-87-P-01028 for the Office of Vehicle Safety Compliance. Attachment 1 (photograph) shows the relationship of the seat at the emergency exit door to the door opening in this test.

In the new bus we have widened the door as shown in attachment 2 (Crown drawing E-504-278). Attachment 3 (photograph) shows the relationship of seats with the new door frame.

Our question regards the seat back in front of the seat at the emergency exit. Aforementioned figures 1 and 2 show a two inch (2") dimension between the access regions and the seat back forward of the emergency exit seat. This dimension is noted as "clearance area around seat back, arm rests, and other obstructions". With our wider opening, the entire seat back is in the emergency exit door opening. However, the actual minimum region area between the two seats are unchanged from the previous desi gn. We feel this wider opening is in full compliance with Part S5.2.3 of FMVSS 217.

An interpretation on this matter at your earliest convenience will be appreciated. Please call the undersigned at (714) 591-0567 if any additional information is required.

Very truly yours,

PHOTO GRAPHS OMITTED

ID: nht88-4.21

TYPE: INTERPRETATION-NHTSA

DATE: 11/30/88

FROM: R. H. MUNSON -- FORD MOTOR CO

TO: ERIKA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/28/89 FROM ERIKA Z. JONES -- NHTSA TO ROBERT H. MUNSON, REDBOOK A33(4), STANDARD 208, STANDARD 209

TEXT: Dear Ms. Jones:

Request for Interpretation

Standards Nos. 208 and 209 contain apparently inconsistent provisions. For the reasons discussed below, Ford believes that the agency intended the later-promulgated provisions to limit the application of the earlier-promulgated ones, and therefore no co nflict actually exists between them. Ford respectfully asks you to confirm that its belief is correct.

In brief, S4.6.3 of Standard No. 208 exempts from the Standard No. 209 restrictions on elongation of seat belt webbing those Type 2 seat belt assemblies that are installed to comply with the manual restraint requirements (S4.1.2.3) of Standard No. 208 and are required by S4.6.1 or S4.6.2 of the standard to meet its frontal crash test requirements. S4.6(a) of Standard No. 209 repeats that exemption. In contrast, S4.5(b) of Standard No. 209 provides that a Type 2 seat belt assembly that "includes a l oad limiter n1 and that does not comply with the elongation requirements of this standard may be installed in a motor vehicle only in conjunction with an automatic restraint system as

part of a total occupant restraint system." (emphasis added). Despite this apparently inconsistent provision, the rulemaking history discussed below suggests strongly that the agency intended to permit such Type 2 seat belts to be used in manual restrai nt systems if such belts also have to meet the frontal crash test requirements of Standard No. 208.

n1 The agency defined "load-limiter" in the preamble to Docket No. 80-12, Notice 2 as a "seat belt assembly component or feature that controls tension on the seat belt and modulates or limits the force loads that are imparted to a restrained vehicle o ccupant by the belt assembly during a crash." (46 Fed. Reg. 2618, January 12, 1981). Notice 2 also added a similar definition to S3 of Standard No. 209.

Discussion

In a final rule n2 modifying Standards Nos. 208 and 209, the agency amended S4.6.2 of Standard No. 208 to require certain trucks and multipurpose passenger vehicles built on or after September 1, 1991, and equipped with a Type 2 seat belt assembly at a f ront outboard designated seating position pursuant to S4.1.2.3 of that standard to meet the frontal crash test requirements of S5.1. The agency also added S4.6.3, a provision that exempts Type 2 seat belt assemblies subject to the requirements of S4.6.1 or S4.6.2 from the webbing width, strength, and elongation requirements of Standard No. 209 [S4.2(a)-(c)] and from the requirements for assembly performance of that standard (S4.4). In addition, the agency amended S4.6 of Standard No. 209 to reiterate t hat exemption and require that such seat belt assemblies be specially labeled.

n2 Docket No. 74-14, Notice 53; 52 Fed. Reg. 44898, November 23, 1987.

In exempting dynamically-tested belts subject to S4.6.2 of Standard No. 208 from certain Standard No. 209 requirements, the agency stated in the preamble to Notice 53, under the heading "Revisions to Standard No. 209":

The agency noted that the webbing of automatic belts is currently excluded from the elongation and other belt webbing and attachment hardware requirements of Standard No. 209, since those belts have to meet the injury protection criteria of Standard N o. 208 during a crash. For dynamically-tested manual belts in passenger cars, NHTSA believed that an exclusion from the webbing width, strength and elongation requirements (sections 4.2(a)-(c) is also appropriate since these belts will also have to meet the injury protection requirements of Standard No. 208. The agency believes that for those same reasons, dynamically-tested safety belts in light trucks and multipurpose passenger vehicles should also be excluded from those requirements of Standard No. 20. (52 Fed. Reg. at 44906). n3

n3 The agency reiterated this reasoning in Docket No. 74-14, Notice 54 (53 Fed. Reg. 5579, February 25, 1988). This Notice denied petitions for reconsideration of the agency's decision to exempt dynamically-tested manual lap/shoulder belts from the a ssembly and elongation requirements (among others) of Standard No. 209. The Notice also denied a petition to delete the provision of Standard No. 208 which exempts automatic safety belts from the Standard No. 209 webbing requirements.

S4.5(b) of Standard No. 209, provides, however, that a Type 2 seat belt assembly that includes a load-limiter and that does not comply with the elongation requirements of Standard No. 209 may be installed in motor vehicles only in conjunction with an aut omatic restraint system as part of a total occupant restraint system. S4.5(c) of that standard also requires that any Type 2 seat belt assembly that includes a load-limiter and does not comply with these elongation requirements be marked or labeled with the following words:

This seat belt assembly may only be installed in vehicles in combination with an automatic restraint system such as an air cushion or an automatic belt. (emphasis added). n4

n4 S4.5 was promulgated in response to a Mercedes-Benz petition to allow use, in conjunction with air bag systems, of belts that did not meet the S4.2(c) elongation requirements. In the preamble to Docket No. 80-12, Notice 2, the agency explained tha t it had proposed restricting the use of load-limiting belts to vehicles equipped with automatic restraints because there are currently no dynamic performance requirements or injury criteria for manual belt systems used alone. There are no requirements to ensure that a load-limiting belt system would protect vehicle occupants from impacting the steering wheel, ins trument panel, and windshield, which would be very likely if the belts elongated beyond the limits specified in Standard No. 209. Therefore, the elongation requirements are necessary to ensure that manual belts used as the sole restraint system will ade quately restrain vehicle occupants. (46 Fed. Reg. 2618, 2619, January 12, 1981).

Ford believes that the more recently promulgated rule exempting manual Type 2 belt assemblies subject to S4.6.1 or S4.6.2 of Standard No. 208 from the elongation requirements of Standard No. 209 was meant to limit the restrictions of S4.5(b) of that stan dard to manual belt assemblies not required to undergo dynamic crash testing. Clearly, the agency's reasons for restricting use of the Type 2 seat belt assemblies specified in S4.5(b) to vehicles also equipped with automatic restraints do not apply to m anual Type 2 belts subject to the dynamic crash test requirements of Standard No. 208. Contrary to the preamble language quoted in footnote 4, those manual belts are subject to "dynamic performance requirements [and] injury criteria" meant to "ensure th at a load-limiting belt system would protect vehicle occupants . . ."

Hence, the elongation requirements are no longer "necessary to ensure that manual belts used as the sole restraint system will adequately restrain vehicle occupants." Indeed the agency expressly recognized this fact in the above-quoted excerpt from the p reamble of Docket No. 74-14, Notice 53, and also in Notice 54.

For the same reasons, Ford believes that manual Type 2 belts subject to S4.6 of Standard No. 208 are intended also to be exempt from the labeling requirements of S4.5(c) of Standard No. 209 and instead to be subject to the labeling requirements of S4.6(b ) of that standard.

Ford respectfully requests your concurrence in its interpretation. If, however, the agency believes that the apparent inconsistency can be cured only by amending Standards Nos. 208 and 209, Ford asks the agency to treat this letter as a petition for rul emaking.

Sincerely,

ID: nht88-4.22

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/88 EST

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: M. IWASE -- TECHNICAL ADMINISTRATION DEPT. - KOITO MFG. CO. LTD.

TITLE: NONE

TEXT: This is to provide you with a clarification of my letter to you dated March 16, 1988. Your second question was whether the minimum edge to edge separation distance between turn signal lamps and tail/stop lamps is required on a rear lighting array for mo torcycles. I responded that "The answer is yes, and the separation distance you have depicted in your drawings appears to comply with this requirement."

In actuality, the agency has required this separation only where a single motorcycle stoplamp/taillamp is mounted on the vertical centerline, and not when dual lamps are mounted on either side of the vertical centerline, the configuration depicted in you r letter of January 25, 1988. Therefore, I am advising you that there is no legal requirement that the 4-inch separation distance be maintained in the configurations you depicted, and that we appreciate your continuing efforts to understand and comply w ith Federal Motor Vehicle Safety Standard No. 108.

I enclose a copy of a letter from this Office dated November 21, 1984, which explains our views on motorcycle rear lighting configurations in more detail.

Enclosure

ID: nht88-4.23

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: GARRY GALLAGHER -- VICE PRESIDENT METZELER MOTORCYCLE TIRE

TITLE: NONE

ATTACHMT: LETTER DATED 07/22/88 FROM GARRY GALLAGHER TO LARRY COOK -- NHTSA, OCC 2372

TEXT: Dear Mr. Gallagher:

This responds to your letter seeking an interpretation of Standard No. 119, New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars (49 CFR @ 571.119). More specifically, you asked whether the letter "B" must appear as part of the size designati on of a motorcycle tire if that tire is of bias belted construction. The answer to your question is no.

As you noted in your letter, section @ 6.5 of Standard No. 119 sets forth the marking requirements for tires used on motor vehicles other than passenger cars, including tires for use on motorcycles. Subsection S6.5(c) states that each such tire shall be marked with "The tire size designation as listed in the documents and publications designated in S5.1." Section S5.1, in turn, specifies tire and rim matching information that must be provided to the public. Generally speaking, the size designation of a tire shows only the physical dimensions of that tire, not necessarily its construction. Thus, the common meaning of the term "size designation" does not necessarily include an indication of the tire's construction type. Further, no provision of Standa rd No. 119 requires a tire's size designation to indicate the tire's construction type. The only reference in section S6.5 of Standard's No. 119 to a tire's construction type is in subsection S6.5(i), which requires the word "radial" to appear on the ti re's sidewall if the tire is of radial construction. Therefore, in response to your question, Standard No. 119 does not require the letter "B" to be included in the size designation of bias belted motorcycle tires.

You noted that your company sometimes adds the letter "B" to the size designation of these tires as an internal code. NHTSA has long said that manufacturers are free to include additional information on the sidewall of their tires, provided that the add itional information does not obscure or confuse the meaning of the required information, or otherwise defeat the purpose of the required information. In this case, the addition of the letter "B" to the size designation would not appear to confuse or obs cure the meaning of the size designation. Hence, there would be no

apparent violation of Standard No. 119 by including the letter "B" in the size designation of bias belted motorcycle tires.

If you have any further questions or need additional information on this subject, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

ID: nht88-4.24

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/88

FROM: THOMAS E. GUNTON -- CORPORATE COUNSEL MCCULLAGH LEASING, INC.

TO: JUDITH KALETA -- OFFICE OF THE CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: ODOMETER DISCLOSURE REQUIREMENTS

ATTACHMT: ATTACHED TO LETTER DATED 03/20/89 FROM ERIKA Z. JONES -- NHTSA TO THOMAS E. GUNTON, REDBOOK A33, PART 580

TEXT: Dear Ms. Kaleta:

This is to request your guidance with respect to whether the odometer disclosure requirements of the Truth and Mileage Act of 1986, 15 USC Section 1981 et seq and the regulations promulgated thereunder, apply to large scale sales of motor vehicles and be tween leasing companies.

In particular, where a motor vehicle leasing company, in a single transaction, sells several hundred of its vehicles (and the related commercial leases) to another leasing company while such vehicles are on lease to numerous lessees whose drivers are loc ated throughout the country, must the transferring leasing company provide odometer mileage disclosures for each of the vehicles transferred, or does the Act exempt such transactions?

If you have any questions or need further information in order to respond, please contact me at your earliest convenience. Thank you for your assistance.

Very truly yours,

ID: nht88-4.25

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/88

FROM: CONRAD S. BROOKS -- ENGINEERING MANAGER FISHER ENGINEERING

TO: ERICKA Z. JONES CHIEF COUNCIL -- NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION, DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/20/89 FROM ERIKA Z. JONES -- NHTSA TO CONRAD S. BROOKS, REDBOOK A33(8); STANDARD 205, STANDARD 120, PART 571.3

TEXT: Dear Ms. Jones:

I have heard differing opinions pertaining to federal regulation of four wheel drive vehicles with snowplows since becoming engineering manager at Fisher Engineering. Will you please furnish a written ruling on the following topics regarding snowplow ap plications:

Mr. Michael Kastner, the National Truck Equipment Association Government Affairs Coordinator, verbally confirmed the following statement yesterday as a result of phone conversation(s) with NHTSA. Please confirm in writing that the substructure for a sno wplow mounting that is permanently attached to a four wheel drive may be attached to and be forward of the front bumper without violating existing or proposed vehicle safety standards.

Is the snowplow blade, being detachable and used only a few hours each year, considered as part of the vehicle payload when it is attached? Does this exempt a vehicle, with the blade attached and raised, from having to meet the Front Gross Axle Weight R ating restrictions?

Is there a specific limitation of what percent of the vehicle curb weight that can be supported by the front axle? The Ford Truck and Body Builder Layout book specifies sixty-three percent maximum. If the portion of the curb weight on the front axle is only dictated by vehicle performance, can you suggest a source for some general guidelines to avoid performance testing?

Thank you for your assistance.

Sincerely,