ID: 2525y

AIR MAIL

Mr. Brad G. Magor 6282 Young Street Halifax, Nova Scotia B3L-1ZB Canada

Dear Mr. Magor:

This is in reply to your letter of May 1, l990, to the Department of Transportation with respect to your intended purchase of a Canadian truck or van which you will eventually import into the United States. You asked for information on the features required to meet the U.S. safety standards, and whether Canadian vehicles generally have these items.

There is a great similarity, but not identicality, between the Canadian Motor Vehicle Safety Standards (CMVSS), and the Federal Motor Vehicle Safety Standards (FMVSS). Manufacturers in both countries are required to affix a label to their vehicles certifying compliance with all applicable safety standards. We understand that some Canadian manufacturers may have certified compliance of their vehicles with both the CMVSS and the FMVSS. If dual certification has occurred, it will be evident from reading the certification label on the vehicle (usually located in the driver door post area). If the vehicle bears a certification of compliance that includes the FMVSS, you should encounter no problems in importing, registering, and selling it in the United States.

However, if the vehicle is certified only to the CMVSS, you will encounter some difficulty in importing it, notwithstanding the substantial similarity of the CMVSS and FMVSS. By direction of Congress, a vehicle not originally manufactured to conform to the FMVSS may not be admitted into the U.S. unless two things have occurred. The vehicle must be on a list of vehicles that the Department has approved for conversion to the FMVSS. If this has occurred, then the vehicle can only be imported by a "registered importer" (i.e. converter), or one who has a contract with a registered importer to perform the conversion work. A bond equal to l50% of the entered value of the vehicle must be given to secure performance of the conversion work, which is cancelled upon satisfactory evidence that the work has been performed.

The new directives of Congress were only effective on January 31, l990, and we are still working to implement them. We have tentatively proposed an approved general list of vehicles that would include all Canadian trucks and vans manufactured since January 1, l968, that were certified as meeting the CMVSS, and which are of the same make, model, and model year of any truck or van originally manufactured for importation into and sale in the United States, or originally manufactured in the United States, and that were certified as meeting the FMVSS. For example, a l990 Chevrolet truck manufactured in Canada to the CMVSS with a U.S. manufactured and certified counterpart would be covered by this general list. We have received no objections to treating Canadian vehicles in this fashion. A final determination should be published in the near future. We have also accorded registered importer status to a number of applicants. If you choose to buy a vehicle certified to the CMVSS for importation into the United States, we will be pleased to provide the latest list of registered importers as the time draws near for your departure.

The minor differences in the standards that may effect you are principally those regarding speedometer/odometers and lighting. The former must indicate miles and miles per hour (and may indicate kilometers and kilometers per hour). Vehicles must be equipped with headlamps that meet the FMVSS and not those of the ECE. Thus, once a CMVSS-certified vehicle is imported, we do not anticipate that the conversion work should be lengthy or costly. Once the work has been satisfactorily performed and the converter's label attached, you should encounter no difficulties in registering the vehicle or in selling it.

I hope that this answers your questions.

Sincerely,

Paul Jackson Rice Chief Counsel ref:59l d:6/28/90

ID: nht92-9.41

DATE: January 23, 1992 EST

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Robert W. Smith -- President, Auto Safety Corporation

TITLE: None

ATTACHMT: Attached to letter dated 12/20/91 from Robert W. Smith to Paul Jackson Rice

TEXT:

This responds to your letter of December 20, 1991.

In replying to your previous letter on November 19, I observed that "we are uncertain of the effect, if any, that the installation of your combination license plate frame/supplementary stop lamp would have upon conformance of a vehicle's license plate lamp(s) with the requirements of Standard No. 108." You have replied that "our engineering precludes any physical interference and obstruction of visibility of the vehicle's license plate," hoping that "this explanation clears up your uncertainty about the operation of our device." You have asked for "a response from your office to that effect."

We appreciate your assurance that your device does not result in any physical interference and obstruction of visibility. However, the device must not affect conformance with the incident light requirements as well. When installed on a vehicle, a license plate lamp must conform with SAE Standard J587 OCT81 License Plate Lamps (Rear Reqistration Plate Lamps). Conformance with the incident light requirements is determined with the lamp in the license plate holder. If the lamp in its holder conforms to J587 with your device installed, then you may be satisfied that we have no further concern.

I enclose a copy of SAE J587 for your reference.

Attachment

Copy of SAE J587. (Text omitted)

ID: HARMER.ZTV

John L. Harmer, Esq.
P.O. Box 721
Bountiful, Utah 84011

FAX 801-299-0523

Dear Mr. Harmer:

This is in reply to your letter of June 4, 1996, asking the following question:

"Whether or not certification of an automobile for sale in Puerto Rico as being in compliance with Federal safety standards would allow that automobile to be imported into the fifty states insofar as compliance with applicable Federal motor vehicle safety standards is concerned?"

The answer is yes, as you have represented to Daewoo.

49 U.S.C. 30112(a) prohibits the importation into the "United States" of a motor vehicle manufactured on or after the date an applicable Federal motor vehicle safety standard takes effect unless the vehicle complies with the standard and is covered by the manufacturer's certification of compliance with the standard. Although the term "United States" is not defined, we view it as comprising all States, and "State" is a defined term. Under 49 U.S.C. 30102(a)(10), a "State" means "a State of the United States, the District of Columbia, Puerto Rico, the Northern Mariana Islands, Guam, American Samoa, and the Virgin Islands." This means that a motor vehicle that Daewoo manufactures to conform, and that it certifies as conforming, with all applicable Federal motor vehicle safety standards, may be freely imported into Puerto Rico or into any other "State" as defined above as in compliance with DOT safety regulations.

I hope that this is responsive to your request. If you have further questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,

Samuel J. Dubbin Chief Counsel ref:591 d:6/6/96

ID: 7113

Mr. Shigeyoshi Aihara
Manager, Information Services
Ichikoh America, Inc.
Suite 220
3025 Boardwalk Drive
Ann Arbor, MI 48108-1777

Dear Mr. Aihara:

This responds to your letter of March 16, 1992, requesting an interpretation of the applicability of the moisture prohibition of S7.4(i)(6) of Federal Motor Vehicle Safety Standard No. 108.

Initially, we would like to call your attention to the fact that S7.4(i)(6), which you quoted in its entirety, was amended on March 11, 1991, to delete the requirement that a headlamp meet the photometric requirements after a humidity test. S7.4(i)(6) now states in pertinent part that, after a humidity test conducted in accordance with S8.7, "the inside of the headlamp shall show no evidence of delamination or moisture, fogging or condensation visible without magnification."

You have attached a drawing of a vented headlamp with an onboard aiming system. The headlamp is available with two different types of bubble indicators. Your first question is: "After the humidity test, both types . . . show the fogging in the location as shown in attached sketches. But, this fogging is gone at normal temperature. * * * Is such fogging acceptable after the humidity test?" Your second question is whether "'the inside of the housing' means the lens and reflector portions" or "the entire inside portion of headlamps?"

The humidity test was adopted for replaceable bulb headlamps in l983. Allowing humidity or water in headlamps causes slow degradation of the reflector over the long term. The presence of humidity results in spots on the reflector and lens, and eventual photometric failure. The humidity test is designed to assure that the vents in vented headlamps eliminate moisture in the headlamp when exposed to air flow with the headlamps off, thus assuring adequate performance in long term use. The provision for onboard headlamp aiming devices was not adopted until 1989, and, with respect to replaceable bulb headlamps, did not specify that they be located within the headlamp. From the foregoing, it is evident that the humidity test for replaceable bulb headlamps was not adopted to address a problem inherent in the exposure of onboard aiming devices to moisture. These devices were not in use at the time the humidity test was added to Standard No. 108, and they do not contribute directly to the photometric performance of the headlamp.

From the diagram you enclosed, the aiming device appears located behind the reflector. It is not possible to determine from your letter whether moisture forms on the exterior or the interior of the aiming device. Although S7.4(i)(6) prohibits moisture "inside the headlamp" and the aiming device is located inside the headlamp, we would not read the prohibition as extending to the aiming device if the moisture occurs inside that device.

Even if the moisture occurs on the exterior of the aiming device, it does not affect the photometric properties of the headlamp. The agency does not wish to impose inadvertent design restrictions that are not directed towards safety, and therefore regards any moisture that may occur on the exterior of the aiming device as outside the prohibition of S7.4(i)(6). This interpretation, however, is limited to the specific design that you have presented.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:108 d:5/6/92

ID: nht78-4.11

DATE: 10/31/78

FROM: AUTHOR UNAVAILABLE; S. P. Wood for J. J. Levin, Jr.; NHTSA

TO: Toyota Motor Sales, U.S.A., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 6, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment. You referred to the Society of Automotive Engineers (SAE) Standard J571d, referenced in Standard No. 108, which specifies dimensions for rectangular headlamp retaining rings in its Figure 8(B). The table of dimensions in Figure 8 specifies a maximum of 1.52 mm for the "N" dimension on the drawing, the distance of the forward portion of the retaining ring from the lens surface. You stated that Toyota plans to increase that dimension by an unspecified amount for ornamental purposes.

You further advised that the proposed design would not interfere with the ability of the headlamps to meet the performance requirements of SAE J580a and b and of the mechanical aiming requirements of SAE J602c.

Since Figure 8(B) of SAE J571d shows that the "K" dimension shall not exceed 1.52 mm, any greater dimension would not meet the specifications of the standard. However, you may petition for rulemaking to appropriately amend Standard No. 108. We cannot, however, offer any assurance that the standard would be changed in response to your petition.

SINCERELY,

TOYOTA MOTOR SALES, U.S.A., INC.

September 6, 1978

Joseph Levin Office of the Chief Council NHTSA

RE: Interpretation Request of FMVSS 108

Dear Mr. Levin:

This is to request your interpretation of SAE J 571d with regard to the retaining ring for 4 x 6 1/2 inch rectangular headlamps, as quoted in FMVSS 108, "Lamps, Reflective Devices, and Associated Equipment."

According to Fig. 8 (B) of SAE J 571d, the forward portion of the retaining ring from the lens surface is limited to 1.52mm ("K" MAX). However, we feel that as long as the performance requirements specified in SAE J 580 a and b, and the aiming requirements specified in SAE J 602c are conformed (Illegible Word), it is not necessary to restrict "K" MAX to 1.52mm.

We are planning to introduce some models with 4 x 6 1/2 inch rectangular headlamps in the near future. The retaining ring is extended ahead, and is formed into a part of the ornamental door or bezel. (See attached drawing.) This retaining ring, as illustrated, is designed so that the opening dimension "L" must comply with the dimension required by the applicable SAE J 571d, "Dimensional Specifications for Sealed Beam Headlamp Unit." The ring's frame portion "M," which is relatively wider in flatness, as indicated, is made to be securely fitted with an aimer specified in SAE J 602c, "Headlamp Aiming Device for Mechanically Aimable Sealed Beam Headlamp Unit," when the headlamps are mechanically aimed.

This headlamp housing can fully comply with the requirements of functional performance (such as headlamp aiming adjustment, vibration resistance, and so on) specified in the applicable SAE J 580 a and b, "Sealed Beam Headlamp assembly," as referred to in the current FMVSS No. 108.

We would appreciate your interpretation of this information at your earliest possible convenience.

TOYOTA MOTOR SALES, U.S.A., INC.

M. YANADA for J. Kawano Director/General Manager Factory Representative Office

cc: M. V. ELLIOTT, OFC. OF VEHICLE SAFETY STANDARDS, NHTSA

Attached Drawing

4 x 6 1/2 in. Rectangular Headlamp Retaining Ring

(Dimension: mm)

Retaining ring extended to a part of ornamental bezel

Note: "L": 92.98 +/- 1.30X133.42 +/- 1.30 (SAE required dimension)

(Graphics omitted)

ID: 2795o

Mr. Louis F. Klusmeyer
Senior Research Scientist
Vehicle Research and Development
P.O. Drawer 28510
San Antonio, TX 78284

Dear Mr. Klusmeyer:

This is in reply to your letter of July 11, l988, to Mr. Vinson of this office with reference to a "deceleration" or "pre-braking" concept.

As you presently envision the implementation of this concept, an amber lamp would be activated when the driver's foot is removed from the accelerator pedal, and would be extinguished automatically when the driver reapplies pressure to the accelerator pedal. You believe that the optimum location appears to be immediately adjacent to the center highmounted stoplamp. You believe further that this location has already been considered by NHTSA for this purpose, and ask whether it is precluded by Standard No. l08.

Your belief is based upon the Federal Register notice of October l983 adopting the center highmounted stoplamp, which stated that "Other types of lamps or added functions such as deceleration signals may be desirable and should be investigated." However, this was in the context of alternatives to adoption of the center lamp, and relates to the agency's statement in the same paragraph that "with additional research, more nearly optimum specifications for stoplamp configurations may be developed." Indeed, the agency made it quite clear in prohibiting combining the center lamp with any other lamp or reflector (paragraph S4.4) that no added functions were contemplated or desirable.

Under paragraph S4.4 therefore, a deceleration lamp and the center stop lamp could not be combined. S4.4 would not prohibit an amber lamp adjacent to the center lamp. However, paragraph S4.1.3 prohibits optional lighting equipment if it would impair the effectiveness of lighting equipment required by Standard No. l08. Your letter indicates that the deceleration signal is deactivated by renewed pressure on the accelerator pedal (and not by pressure on the brake pedal) so that a following driver would be presented with both amber and red signals, creating the possibility of confusion, and hence impairment. You have not indicated whether the deceleration lamp would be steady-burning or flashing, but we believe the possibility of confusion would increase were the lamp flashing. However, were the lamp to be extinguished when the brake pedal is applied (which activates the stop lamps), then the possibility of confusion would be substantially lessened. With respect to deceleration warning systems, last year the Flxible Corporation determined that a system installed on its buses created an impairment, and hence a noncompliance with paragraph S4.l.3. The company then conducted a notification and remedy campaign (87V-089) as required by statute. The company concluded that its flashing amber deceleration lamps could create confusion when activated simultaneously with the red steady burning stoplamps.

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

Ref: 108 d:8/l5/88

ID: nht68-2.23

DATE: 06/28/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Grove Manufacturing Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 3 to the Director of the National Highway Safety Bureau. I apologize for your not receiving a reply earlier but the letter was inadvertently misplaced.

Your letter was evidently dictated prior to publication in the Federal Register of the chassis-cab regulations and ruling enclosed. I hope the enclosed ruling answers the questions you have with regard to the "hydra-tilt roll back loading bed" your company manufacturers. In your letter you state that approximately 10 percent of the "hydra-tilt roll back loading beds" your company manufacturers are mounted on the customer's truck chassis by your company. Under these conditions you would be considered a person who combines "the chassis-cab with a body or other structures [and] will be responsible for (1) compliance of the combines assemblage with any motor vehicle safety standard applicable to the end use of the combined assemblage in effect on the date of manufacture of the chassis-cab, compliance with which has not already been certified by the chassis-cab manufacturer, and (2) compliance with all applicable standards in effect on the date of manufacture of the chassis-cab to the extent that the addition of a body or other structure to the chassis-cab affects the chassis-cab's previous conformance with applicable standards." (See 33 F.R. 29).

For the roll back beds you sell to distributors for mounting, the distributors would be considered the assemblers and would be responsible for compliance as described above.

Also enclosed is a copy of a notice published in the Federal Register concerning certification requirements under the National Traffic and Motor Vehicle Safety Act of 1966. To date these are the only specific requirements for certification.

In your letter you also describe three types of motor vehicles you manufacture. They are (1) a hydraulic yard crane; (2) an RT Series hydraulic crane, for use on off-highway construction jobs; and (3) a truck mounted hydraulic crane.

Based on the material submitted we would conclude that of the three types of vehicles described, the hydraulic yard crane and the RT hydraulic crane would not be considered motor vehicles primarily for use on the public highways. The third type of vehicle described, the crane carries, would be considered motor vehicles and subject to National Traffic and Motor Vehicle Safety Act and regulations issued thereunder.

Enclosed you will find a compilation of the present motor vehicle safety standards and an Advanced Notice of Proposed Rulemaking for 47 proposed standards. Your name has been added to the Bureau's mailing list and you will be receiving word of future actions taken concerning the motor vehicle safety program.

ID: 1982-3.35

TYPE: INTERPRETATION-NHTSA

DATE: 12/22/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Automobile Importers of America Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter asking about the identification requirements of FMVSS 101, Controls and Displays. You asked whether it is permissible for a manufacturer to identify a certain manual control with the symbol specified by the European Economic Community (EEC) for the cold start control. According to your letter, the control resets injection timing and actuates cylinder warming.

By way of background information, the agency does not provide approvals of motor vehicles or motor vehicle equipment. The Vehicle Safety Act requires that each manufacturer assure that its products are in compliance with all applicable standards. The following only represents the agency's opinion based on the specific facts provided in your letter.

The answer to your question is yes, since Standard No. 101 does not include any identification requirements applicable to that specific type of control.

Section S5 of Standard No. 101 requires each passenger car manufactured with any control listed in S5.1 or in column 1 of Table I to meet the requirements of the standard for the location, identification and illumination of such control.

Neither section S5.1 nor column 1 of Table I list or include a single control which operates the two functions noted above.

Since Standard No. 101 does not include any identification requirements applicable to that type of control, identification is at the discretion of the manufacturer. It is therefore permissible, under that standard, to identify that type of control with the symbol specified by the EEC.

SINCERELY,

AUTOMOBILE IMPORTERS OF AMERICA, INC.

May 27, 1982

Frank A. Berndt, Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Berndt:

One of our member companies would like an interpretation of FMVSS 101-80, Controls and Displays, as it applies to a specific design.

This passenger car is equipped with a diesel engine but the cold-starting control is not an automatic device linked to the ignition switch as are many designs. This particular model uses a manual control which resets injection timing and actuates cylinder warning.

European authorities require that the cold-start control symbol (Figure 19 of EEC Directive 78/316) be used to identify this control for those vehicles sold in Europe. Is it permissible for this symbol to be used for vehicles sold in the United States?

FMVSS 101-80, Controls and Displays, calls for any control item which is listed in Table I of the standard to be identified as shown in that Table. The diesel cold start control is not listed in Table I; the only similar controls required to be labeled are an engine choke and hand throttle, neither of which pertain to this device.

Does this mean that this device is not required to be identified by words and that the symbol control identification may be used on U.S. cars? If this is the case, the manufacturer will be able to commonize controls with European models and save unnecessary expense.

Bruce Henderson

ID: 2656o

Mr. Mike Kaizaki
Manager, Truck Tire Engineering
Yokohama Tire Corporation
Corporate Office
60l S. Acacia
Fullerton, CA 9263l

Dear Mr. Kaizaki:

This responds to your letter requesting an interpretation of Standard No. ll9, New Pneumatic Tires for Vehicles Other Than Passenger Cars. You asked whether it is permissible to place two tire size designations, 385/65R22.5 in larger letters and l5R22.5 in small letters, on the same tire. The answer to your question is no.

By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.

The practice of labeling two tire sizes on one tire, as you requested in your letter, was once a fairly common practice and was referred to as "dual-size markings." Dual-size markings were a marketing effort by tire manufacturers to try to persuade consumers to change the size and/or type of tire on their vehicles, by representing that this particular tire size was an appropriate replacement for two different sizes of tires. However, the practice of using dual-size markings confused many consumers about the size of the tire on their vehicle. The only purpose of the Federally required markings on tires is to provide consumers, in a straightforward manner, with technical information necessary for the safe use and operation of the tire. The agency concluded that it was inappropriate to permit a marketing technique that was confusing many consumers to defeat the purpose of the required markings on tires. Accordingly, dual-size markings were expressly prohibited for passenger car tires subject to Standard No. 109; 36 FR 1195, January 26, 1971.

The marking requirements for tires subject to Standard No. 119 are set forth in section S6.5 of the standard. Section S6.5(c) requires that each tire be marked on both sidewalls with "the tire size designation as listed in the documents and publications designated in S5.1." Section S5.1 of Standard No. 119 requires each tire manufacturer to ensure that a listing of the rims that may be used with each tire the manufacturer produces is available to the public. This may be done either by the individual manufacturer furnishing a document to each of its dealers, to this agency, and to any person upon request, or the manufacturer may rely on the tire and rim matching information published by certain standardization organizations.

While Standard No. 119 does not expressly prohibit dual-size markings, section S6.5(c) uses the singular when it refers to the "tire size designation" to be labeled on the tire. Considering the past history associated with dual-size markings, this agency interprets section S6.5(c) of Standard No. 119 as prohibiting a manufacturer from marking a tire with two different size designations, even if a document or publication designated in S5.1 were to show two different size designations for the same tire size.

Sincerely,

Erika Z. Jones Chief Counsel ref:119 d:2/16/88

ID: nht95-6.10

TYPE: INTERPRETATION-NHTSA

DATE: August 11, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA; Signature By Stephen P. Wood

TO: Thomas A. Placey, Esq. -- Senior Assistant District Attorney, Office of the District Attorney, Cumberland County; One Courthouse Square

TITLE: NONE

ATTACHMT: ATTACHED TO 07/21/95 LETTER FROM THOMAS A. PLACEY TO OFFICE OF CHIEF COUNSEL, NHTSA

TEXT: Dear Mr. Placey:

This responds to your letter of July 20, 1995. You present the fact situation of the theft in Canada of a Canadian-owned GMC Jimmy which was then imported into the United States and delivered to a conspirator in Pennsylvania. The conspirator altered the VIN and sold the Jimmy which was eventually seized by the Pennsylvania State Police. The Jimmy's buyer wants the vehicle back and has filed with the local state court for its return.

You write "The issue, on the federal level, is can this vehicle ever be properly registered in the United States. What are the specific federal laws or regulations that govern such situations."

We cannot answer the question whether this vehicle can be properly registered in the United States, because there are no Federal requirements that apply to the registration of privately owned vehicles. Each State establishes its own requirements. For an overview of State laws on vehicle registration, we suggest that you write the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203.

There are two Federal laws which we administer that are relevant to the situation you present. Missing from your scenario is the fact whether the Jimmy was manufactured in the United States in compliance with the U. S. Federal motor vehicle safety standards. If the answer is yes, then its importation by any person does not violate the Federal statues under which we operate. If it was not manufactured to conform, we note that the importation of a nonconforming vehicle is an act forbidden by 49 U.S.C. 30112(a) for which a civil penalty may be imposed under 49 U.S.C. 30165. The statute does not provide the right to seize a nonconforming vehicle. Furthermore, the statute does not forbid the sale of a used nonconforming imported vehicle.

There may be a violation of 49 U.S.C. 30122 because of the defacing of the VIN. Under this section, no manufacturer, dealer, distributor, or motor vehicle repair business may knowingly make inoperative any part of a device or element of design installed in accordance with a Federal motor vehicle safety standard. The VIN was installed in accordance with 49 CFR 571.115 Motor Vehicle Safety Standard No 115 Vehicle Identification Number. We view the alteration of the VIN as a violation of this section, if the conspirator who altered it was a manufacturer, dealer, distributor, or motor vehicle repair business as those terms are described in the statute. Violators of this section are also subject to a civil penalty under 49 U.S.C. 30165.

We are unable to advise you on the laws or regulations administered by other Federal agencies. For example, we cannot advise you whether the U.S. has entered into any treaties or other agreements with Canada concerning the treatment of property that is stolen from that country. You may write for an opinion to the United States Department of State, Office of Foreign Mission, 3507 International Place, N.W., Washington, D.C. 20008.

If you have further questions, Taylor Vinson of this Office will be able to help you with them (202-366-5263).