ID: nht80-1.4

DATE: 01/11/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your October 8, 1979, letter and follow-up meeting in which you ask several questions about the compliance of your school buses with Standard No. 221, School Bus Body Joint Strength. In your letter, you ask about four separate joints and ask whether they would be required to comply with the standard.

As you know, the standard applies to any joint of a body panel that encloses bus body space and a body structure member. An exception from the standard exists for those joints that connect maintenance access panels. In our meeting with you, we stated the agency's objection to the existing industry practice involving maintenance access panels, and further stated that the agency was contemplating rulemaking to restrict the maintenance access panel exception.

Responding directly to the four joints that you reference in your letter, you first ask whether the contact point between the headlining panel and the spring clip is a joint subject to the standard. A spring clip is entirely enclosed within a bus wall. Its function is to aid in holding the body panel in place while the rivets or adhesives are being applied. It serves no function beyond that. The agency does not believe that a spring clip is either a body structure member or a body panel enclosing occupant space. Accordingly, the joint of this clip and any other body member is not a joint subject to the standard.

In your second question, you ask whether the joint between the headlining panel and the headlining panel positioning tab is a joint subject to the standard. The positioning tab is a device that is approximately two inches long and contacts the headlining panel in two places between the bus body bows. The purpose of this tab, is to prevent buckling of the headlining panel between the two bows. The agency concludes that positioning tabs are body structure members. Therefore, if they contact a body panel at its edge, the intersection of these two components creates a joint subject to the standard.

Your third question asks whether an extruded aluminum sash assembly must comply with the standard. You state in your letter that this assembly is part of the window and, therefore, exempt from the requirements. The aluminum sash assembly to which you refer is an add-on device above the window found in your larger buses to provide more headroom. The agency concludes that this device has no function as a part of the window but merely is a trim panel that serves to cover part of the bus sidewall. Accordingly, the joint connecting this panel to the remainder of the bus structure would be required to comply with the standard.

Finally, you ask whether the joint between a positioning angle and a headlining panel must comply with the joint strength requirements. A positioning angle is a body structure member that runs from bow to bow and supports the edge of the headlining panel to prevent buckling. The agency concludes that this positioning angle is a body structure member and its connection with a body panel is a joint subject to the standard's requirements.

SINCERELY,

BLUE BIRD

BODY COMPANY

October 8, 1979

Frank Berndt Chief Counsel National Highway Transportation Safety Administration Department of Transportation

SUBJECT: FMVSS 221

REF: 1. Letter from Francis Armstrong to Albert L. Luce dated 6-1-79; NEF-31 MPa CIR 2087

Dear Mr. Berndt:

The subject standard requires 60% joint strength for certain defined joints on school buses; other joints, as defined in S4 of the standard, are exempted. The purpose of this letter is to seek confirmation that certain aspects of a proposed design change are exempted under the provisions of S4.

In preparation for initial compliance with the subject standard, Blue Bird Body Company redesigned the wire service panel and obtained approval for the new design; please refer to letter to and from NHTSA on February 13, 1976 and April 26, 1976 respectively.

In reference 1, NHTSA raised questions concerning our wire service panel. The questions carried no allegations of non compliance. However, in keeping with Blue Bird Body Company's philosophy of meeting the spirit of NHTSA regulations as well as the letter, we are now proposing changes to the wire service panel and surrounding components. These changes are described by the two enclosed prints.

The prints show cross sections of the proposed wire service panel design for 74" headroom and 77" headroom vehicles. The specific items with regard to this design proposal which we would like you to confirm are:

1. That the area of contact between the headlining and spring steel clip is not a joint subject to FMVSS 221 requirements. As shown on the prints, this clip is used only as an assembly aid to support headlining panels while permanent fasteners are installed. The clip will be approximately 3/4" wide. While the permanent integrity of the design is not dependent on the clip, the intent is to leave it in place after the permanent fasteners are installed.

2. That the area of contact between the headlining and the headlining panel positioning tab on the header of 74" headroom models is not a joint subject to the requirements of FMVSS 221. The purpose of the tab is to prevent the headlining from bowing outward between roof bows. The tab is shown full size on the 74" headroom print. There will be two tabs per window section.

3. That the window frame extension on 77" headroom models is exempted under the provisions of S4 where windows and body panel joints designed for ventilation are exempted.

4. That the headlining panel positioning angle on 77" headroom models is exempted. This angle performs the same function on 77" headroom models as the headlining panel positioning tabs serve on the 74" headroom models; see item 2 above.

Your early review and confirmation of these items will be appreciated. We are available for conference at your convenience to answer any questions you might have.

W. G. Milby Manager, Engineering Services

ENCLS.

ID: nht80-1.40

DATE: 03/24/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: O'Meara Ford Center

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 26, 1980, letter asking about the proper certification for a Ford Mustang that has been converted to a convertible. You ask what certification is required before you would be permitted to sell such a vehicle.

The National Highway Traffic Safety Administration requires all manufacturers of motor vehicles to certify that their vehicles comply with Federal safety standards prior to first sale. In the case of the vehicle that you mention, Ford Motor Company would have certified it when it was sold to the company that converted it to a convertible. Ford's certification label is located on the driver's door or pillar post.

The company that converted the vehicle, Tomaso of America, is responsible for putting its own label on the vehicle indicating that as altered the vehicle continues to comply with the applicable Federal safety standards. The requirements for alterers' labels are located in Title 49 of the Code of Federal Regulations, Section 567.7. Tomaso's label should also be located on the vehicle in the same area as Ford's.

If both of the labels are on the vehicle, it is legal for you to sell it. If either of the labels is missing from the vehicle, then the vehicle is not correctly certified and may be in noncompliance with the safety standards.

ID: nht80-1.41

DATE: 03/26/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: David Williams

TITLE: FMVSR INTERPRETATION

TEXT: I would like to clarify my remarks of March 17, 1980, with respect to the applicability of Federal motor vehicle safety standards to imported vehicles.

In that letter I implied that there was a prohibition against importing cars that didn't meet Federal standards and that such vehicles had to comply with standards in effect on the date of importation. Actually, a nonconforming vehicle may be imported under bond if it will be brought into compliance within 120 days of entry with all applicable standards in effect on the date of its manufacture.

ID: nht80-1.42

DATE: 03/27/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Maryland Department of Transportation

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 8, 1980, letter asking whether it is permissible for a State to transport children to and from school on regular city transit buses. The answer to your question is yes, if the buses are on their scheduled transit routes and are transporting both school children and adults.

The National Highway Traffic Safety Administration has defined school bus in a way that allows buses sold for use as common carriers in urban transportation to transport school children without complying with school bus standards. This definition is located in Title 49 of the Code of Federal Regulations, Part 571.3. The agency permitted this exemption from the school bus safety standards in acknowledgment of the high costs involved in maintaining dual fleets of buses, one for school children and one for adults. Accordingly, the agency permitted cities with operating bus lines to transport children on those city buses. The agency also believes that joint bus fleets can help to conserve fuel.

The agency has made one restriction on the use of city buses to transport school children. The buses must be operating on their regular passenger routes and schedules and must not be operating on special school bus routes. Any vehicle that is operating exclusively as a school bus should be constructed in accordance with the school bus safety standards.

SINCERELY,

March 6, 1980

Raymond J. Salehar Highway Safety Engineer Maryland Department of Transportation Motor Vehicle Administration

Dear Mr. Solehar:

Thank you for sending HJR 21 for comments. Even though you state they would be informal, it is our practice to ask our legal department to make these comments.

I am forwarding HJR 21 to Joseph J. Levin, Chief Council, NHTSA for response.

David H. Soule Highway Safety Management Specialist Traffic Safety Programs

cc: J. J. LEVIN

Maryland Department of Transportation

Motor Vehicle Administration RAYMOND J. SALEHAR Highway Safety Engineer

David Soule:

This bill is a departure from the norm. . . . the problem is that Baltimore City is using Metro transit buses for school use by providing tickets to the students affected. They also have a small fleet of buses around the outskirts of the city and for handicapped students. These buses are painted yellow but our statute does restrict them from using flashing red lights.

Do you visualize any harm in this joint resolution?

Would appreciate your informal comments. If the commission proceeds you may be called later this year for more formal advice.

Thanks for the LPG information, your P. Aylor in Atlanta was a very information person.

HOUSE JOINT RESOLUTION No. 21

01r0067

By: Delegates Bird, Mooney, Maloney, Sheehan, Pitkin, Bainum, Scull, Simmons, Pesci, Donaldson, McCaffrey, and Cicoria

Introduced and read first time: January 17, 1980

Assigned to: Constitutional and Administrative Law

HOUSE JOINT RESOLUTION

A House Joint Resolution concerning

Dual Transportation Systems

FOR the purpose of requesting the Legislative Policy Committee to establish a commission to study the dual systems of transportation in urban areas of the State so that the yellow school bus system may be phased out wherever possible; and requiring the commission to report its findings by a certain date.

WHEREAS, The State of Maryland maintains a dual transportation system in its urban areas consisting of the yellow school bus for transportation of school children and transit buses for the general public; and

WHEREAS, Both systems are heavily subsidized by State grants to the local subdivisions of the State; and

WHEREAS, These transportation systems are too often duplicative in the services they render and inefficient in providing total transportation for the general public; and

WHEREAS, In the majority of urban areas throughout the United States, school children are encouraged to ride public transportation; and WHEREAS, The combination of public transportation and school transportation would result in substantial savings in State revenue, as well as the development of a unified and more efficient public transportation system; now, therefore, be it

RESOLVED BY THE GENERAL ASSEMBLY OF MARYLAND, That the Legislative Policy Committee is requested to establish a commission for the purpose of studying the dual transportation system in the urban areas of the State of Maryland in order to develop a plan to phase out the yellow school bus system wherever possible and to encourage school children of appropriate ages to ride public transportation to and from school; and be it further

EXPLANATION:

Numerals at right identify computer lines of text.

HOUSE JOINT RESOLUTION No. 21

RESOLVED, That the commission shall consist of three members of the House of Delegates appointed by the Speaker of the House, three members of the Senate appointed by the President of the Senate, and three members to be appointed by the Governor, one member being the designee of the Secretary of Transportation; and be it further

RESOLVED, That the commission shall make its final report to the Governor and the Legislative Policy Committee by December 31, 1981.

Maryland Department of Transportation

Office of the Secretary

DATE: 2/7/80

BILL NO.: HJR 21

COMMITTEE: CAL

SUBJECT: Phase out yellow school bus

DOT POSITION: SUPPORT

EXPLANATION: HJR 21 provides to establish a commission to study the dual systems of school bus transportation in urban areas.

COMMENT: It is recognized that this system is costly to the state because it is a dual system. Presently there are 413 yellow school busses being operated in Baltimore City. 100 are privately owned, 204 are contracted to the Department of Education and 109 are owned by the Department of Education.

The MVA supports the appointment of a select committee to study this matter and to make recommendations to combine these operations for possible phasing out of the yellow school bus operation.

For Information: Nance J. Stamboni

ID: nht80-1.43

DATE: 03/27/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Great Dane Trailers Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is to confirm your telephone conversation with Mr. Schwartz of my office, in which he advised you that the manufacturer identifier referred to in Docket 1-22, Notice 10, was the manufacturer identifier required by S4.5.1 of Federal Motor Vehicle Safety Standard No. 115. Inasmuch as the Society of Automotive Engineers has already assigned a manufacturer identifier to Great Dane Trailer, Inc., this requirement has been met.

I am forwarding your complete VIN plan to the VIN coordinator as required by S6 of the Standard.

ID: nht80-1.44

DATE: 04/03/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Aveco Trucks of North America, Inc

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your request for an interpretation of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. You described a bulb check button which could be activated at any time by merely pushing it in, but which when released would be automatically deactivated. You asked whether the possible activation of this button at any time would take it out of compliance with section 5.3.1 of Safety Standard 101-80.

This section states that "a telltale shall not emit light except. . . during a bulb check upon vehicle starting." This provision was intended to prevent the driver from accidently leaving the bulb check control activated and thereby creating a situation where a defective functioning of the vehicle would go unnoticed by the driver. Since the bulb check control that you described cannot accidently be left in the on position since it is deactivated when the driver releases it, section 5.3.1 of Safety Standard 101-80 would not operate so as to prohibit use of this device.

I hope that you have not been inconvenienced by our delay in sending you this response.

ID: nht80-1.45

DATE: 04/03/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Dick Pilch

TITLE: FMVSS INTEPRETATION

TEXT: This is in response to your February 7, 1980 letter to the Department of Transportation, in which you complained about the failure of a tire on your truck. Specifically, you stated that the tires on the front axle of your truck were overloaded by 570 pounds each, and that no non-radial tire is currently manufactured which would not have been overloaded if used on this front axle.

If the tires which were overloaded came as original equipment on the truck, the manufacturer of the truck violated Federal Motor Vehicle Safety Standard No. 120 (49 CFR 571.120). Paragraph S5.1.2 of Standard No. 120 requires the sum of the maximum load ratings of the tires fitted to any axle to be at least equal to the gross axle weight rating of that particular axle. This requirement is applicable to all trucks manufactured on or after September 1, 1976. If your truck was manufactured after that date, please send me the name of the manufacturer as well as the information provided by the manufacturer specifying the appropriate tire sizes to be used on the truck. The information concerning appropriate tire sizes will appear on a label on the door latch post on the driver's side of the truck. If the manufacturer has violated Standard No. 120, appropriate steps will be taken by the agency.

You also stated that certain radial tires would have met the load-carrying requirements for your truck, but that you would not use radial tires because of erratic wear patterns. For your information, I have enclosed a booklet published by the Rubber Manufacturers Association setting forth information on the care and service of radial and non-radial truck tires. On page 11 of this booklet there is a description of the irregular wear to which you refer, as well as instructions on how to prevent the irregular wear from lessening the overall mileage the tire will give you. Hence, if you wish to use radial tires on your truck, there is no reason to expect them to perform unsatisfactorily.

More significant, however, is the misunderstanding you have in suggesting that no bias ply tire is manufactured which would not have been overloaded on your truck. Such a tire is now manufactured and has been manufactured for at least the past 20 years. On page 30 of the enclosed booklet, you will find a table showing the load-carrying capacity of bias ply tire sizes mounted on 15 degrees drop center rims. The tire size mounted on your truck, the 11-22.5, does indeed have a maximum load of 5,430 pounds if it is a load range F tire. However, a load range G tire of that same size has a maximum load of 6,040 pounds, and would not be overloaded if used on your truck. This is the tire you should probably use on the front axle.

I am sorry to hear of your accident and hope that you have recovered from your injuries. Your complaint about the failure of the Uniroyal Delta tire has been recorded, and the agency will be alert to other indications of problems with this tire. To date, however, we do not have sufficient data indicating a safety problem to open a formal investigation.

I want to thank you for taking the time to express your concern about motor vehicle safety. It is only through the efforts of concerned citizens such as yourself that we can ensure maximum safety for all users of the highway. If you have any further questions or concerns about this matter or any other aspect of highway safety, please do not hesitate to contact me.

SINCERELY,

February 7, 1980

TO WHOM IT MAY CONCERN:

It is unfortunate when corporations become so large that they influence our Courts and brainwash the general public through advertising and news media.

Case in Point:

An individual purchased two tires to replace those that were wearing out. He bought bias ply tires in preference to radial tires because eratic wear patterns are standard for radial tires on a free turning wheel on all makes and this hasn't been corrected to this date. The last set was on the vehicle for 85,000 miles and was in good enough condition to put on the rear of the truck. Some 30,000 miles later, after 1-1 1/2 hours driving time on a cool morning, the temperature being 60 degrees or less and raining lightly, the tire blew out with no warning, causing the vehicle to go off the road over an embankment. The vehicle came to rest turned almost over on its side and spilling the load off the vehicle. This destroyed the truck and trailer and injured the operator. The driver was unaware of the injury at the time of the accident. The symptons became apparent about three months later, which rendered him almost crippled for many months. To this day the driver is still in pain, sometimes quite severe.

Getting back to our "Great Society" (as the joke is sometimes put), we are supposed to look out for the people that use the products that these careless giants put on the market, which are a danger to life, limb and property. There is also the danger of one of these tires blowing out on a six-lane freeway, such as that in Los Angeles, where one driving during the traffic rush about 3 p.m., could kill several people. However, those companies can continue to manufacture defective equipment by the thousands and sell it to the people. It appears as though nothing better can be had.

Example: Our federal and state governments have passed laws that a large truck can gross 80,000 pounds if it is equipped with five axles and the proper length. Front axle 12,000 pounds Tandem driver axle 34,000 pounds Tandem trailer axle 34,000 pounds

Let's look closer at the manufacturer's specifications.

A single tire, 5,430 pounds at 85 pound psi X 2 = 10,860

From 12,000 pounds - 1,140 for both For a single tire = 570 pounds overload.

Does the manufacturer say anything? No. They appear to be unconcerned as long as they can sell tires.

Let's continue. Concerning the manufacturers and their specifications, they say on dual tires, one should run 75 pounds psi and be able to carry 5,060 pounds on each tire. Let's compare the weight difference.

State and Federal Manufacturer 85 psi 12,000 pounds - single steer axle 5,430 X 2 = 10,860 pounds 6, 050 X 8 = 48, 75 psi 34,000 " - dual tandem axle 400 " 34,000 "- dual 6,050 X 8 = 48,400 " 80,000 pounds 107,660 pounds

Let's take a closer look for safety's sake. Or does safety go out the window when you are talking about a multi-million dollar corporation? It seems to apply only to the poor, dumb truck driver, doesn't it?

Look at 34,000 pounds divided by 8 = 4,250 pounds maximum weight. The safety margin is good, to say the least.

12,000 pounds divided by 2 = 6,000 pounds. Woops! Where did the safety margin go? Now doesn't this make a lot of sense? Run dual wheels on driver axle or trailer axle and you have 1,750 pounds to play with. If one tire should let go, you could in no way lose control of the rig. However, on the steer axle, you have no safe margin, As a matter of fact, you are exceeding specifications all the time. Most trucks are carrying approximately 10,000 or 11,000 pounds on the front axle at all times. Also, there isn't a tire manufactured that has the specifications that it should have as far as safety goes. There is a radial tire that will carry the 6,000 pounds, so they say. However, the manufacturer will state that on two free rolling wheels, you will have eratic wear patterns. As yet there isn't a tire manufactured that doesn't have them.

There are two ways to remedy the problem. Let's either change the load limits to compare with what the manufacturer says, or make the manufacturer (which we know won't happen) make a tire that has the rating needed to put the same percent of safety on the steer axle that there is on the dual driver or trailer axles. The third way to remedy the problem and the one most likely of the three, is to place this letter in the round file, commonly known as the "trash can".

Yours truly,

Dick Pilch

P.S. Also, we could make the same true for tire manufacturers and make them totally responsible for their products, pull them out of production when found bad and let them suffer the loss of what the user does in terms of injury, income and life.

TO:

UNIROYAL - Detroit, Michigan KIRO TV - Seattle, Washington

KING TV - Seattle, Washington

KONG TV - Seattle, Washington

20/20 - Seattle, Washington

Senator Jackson - Washington, D.C.

Senator Magnuson - Washington, D. C.

U.S. Department of Transportation - Washington, D.C.

U.S. Department of Transportation - Seattle, Washington

Office of Chief Counsel - Washington, D.C. Federal Highway Administration

National Highway Safety Administration - Washington, D.C.

Center for Study

c/o Ralph Nader - Washington, D.C.

Judge William Goodloe (Superior Court) Seattle, Washington

Over Drive Magazine

Robert Peterson

c/o Mother Trucker Magazine - Los Angeles, California

DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION VEHICLE OWNER'S QUESTIONNAIRE

Pleading Omitted. Vehicle code provisions omitted.

ID: nht80-1.46

DATE: 04/04/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: American Motors Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your letter of January 14, 1980, requesting an interpretation concerning the proper designated seating capacity for the front seats of the 1981-model AMC Concord. Your letter states that the Concord front seats have over 50 inches of hip room as measured by SAE procedure J1100a, but you characterize the seats as "individual" seats since they are separately adjustable. You ask whether the seats can qualify as having only two designated seating positions.

Based upon the information in your letter and on the photographs you submitted February 22, it is our opinion that there must be three front designated seating positions in the 1981 AMC Concord. The amended definition of "designated seating position" provides that there shall be at least three positions in any bench or split-bench seat having greater than 50 inches of hip room, unless there is some obstruction or design preventing use of the center position. Although the seats in this model are on separate tracks and are separately adjustable, they are the functional equivalent of a split bench seat when the two sections are side-by-side (as illustrated in your Number One photograph). There is not sufficient space between the seats for them to qualify as separate bucket seats. Bucket seats are typically separated by at least 8 to 10 inches. The juxtaposition and design of these "individual" seats creates a well-padded center position. Further, although the inboard buckle portion of the seat belt assemblies occupy the center position, the buckles can be easily pushed down between the seats and would not be an impediment to use of the center position (as illustrated in your photograph Number Three).

For these "individual" seats to qualify as having only two designated seating positions, it is our opinion that they would have to be much further apart, as is true of typical bucket seats, since they currently provide over 50 inches of hip room. Alternatively, the buckle ends of the seat belt assemblies would have to be on much stiffer cables that could not be moved out of the way or pushed between the seats. Moreover, these buckle ends must extend far enough onto the seat to provide true obstructions to use of the center position.

Finally, I would emphasize that this letter only represents the agency's opinion based on the information supplied in your submissions. The NHTSA does not pass approval on any vehicle design, for any safety standards, prior to the actual events that underlie certification. It is up to the manufacturer to determine whether its vehicles comply with all applicable safety standards and regulations, and to certify its vehicles in accordance with that determination.

SINCERELY,

American Motors Corporation

January 14, 1980

Joan B. Claybrook, Administrator National Highway Traffic Safety Administration U.S. Department of Transportation

Dear Ms. Claybrook:

This letter is written to solicit your concurrence with our planned two-passenger seating designation for the front "individual" seats installed in our 1981 model AMC Concord. Since its introduction, this particular vehicle and seat configuration has been assigned a two-passenger designation. We believe that this designation has been and continues to be consistent with our customer's perception of "likely use" for this specific seating package.

We base this opinion on the unique design characteristics of our "individual" seats. Each seat is separately adjustable so that each occupant can select a comfortable amount of leg room. In addition, each seat is equipped with a seat back recliner mechanism allowing each occupant to select and vary the seat back angle to their personal preference.

Incremental to these separate and unique adjustment characteristics, the seat itself is specifically styled and contoured to convey the impression of two-passenger capacity. The design philosophy is to provide the customer with the convenience of "bucket" seats in a less sporty, more luxurious interior package.

The perception of two-passenger capacity is carried through in the design of the seat belt restraint system. The inboard belts are equipped with stiff webbing guides to help locate the buckle ends. These two inboard buckle stalks are a clear indication that each seat is intended to be used by only one person at a time.

The concern over our intended designation for this vehicle/seat configuration rests with the singular criterion of hip space. As measured by the procedures of SAEJ-1100a, the AMC Concord has over 50 inches of hip space. Nevertheless, the above noted design and functional characteristics of our "individual" seats, as well as the distinct separation of these seats in the vehicle, preclude their "likely use" by more than two passengers.

We ask for your concurrence with our two-passenger designation by March 1, 1980.

W. C. Jones Director - Vehicle Safety Programs

February 21, 1980

R. E. Nelson National Highway Traffic Safety Administration

Reference: MRM-12

Dear Mr. Nelson:

Enclosed per your request are pictures of our planned 1981 AMC Concord front "individual" seats. These are being submitted as supplemental information in support to our January 14, 1980 request for the NHTSA's concurrence with our two-passenger seating designation for this specific seating package.

Photograph number one illustrates the styling philosophy of two distinctly separate and contoured seats which are packaged with a restraint system that includes stiff webbing stalks to prominently locate the inboard buckle ends. Also demonstrated are the unique functional characteristics of the these seats which include a separately adjustable seat back (photograph number two) in addition to the normal individual fore-aft adjustment provision (photograph number three).

These pictures demonstrate why the overall styling, design and function of these individual seats give a clear perception of their two-passenger designation.

W. C. Jones Director - Vehicle Safety Programs

(Graphics omitted)

Number One

(Graphics omitted)

Number Two

(Graphics omitted)

Number Three

ID: nht80-1.47

DATE: 04/09/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Renault USA

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your letter of March 3, 1980, requesting an interpretation concerning the proper designated seating capacity for the rear seat in the Renault Le Car vehicle. You state that the rear seat of the Le Car has 48.2 inches of hip room, and ask whether the vehicle would qualify as having only two designated seating positions.

I am enclosing a copy of a letter of interpretation the agency recently issued to Toyota Motor Company regarding the designated seating capacity of the rear seats in several of its models. The rear-seat designs of these Toyota models are very similar to the Le Car, in that the presence of wheel wells results in hip room measurements below 50 inches under the strict measurement technique specified in the definition of "designated seating position" (SAE J1100a). As was pointed out in that letter, however, if occupants move their hips slightly forward of the wheel wells, which extend only a few inches out into the seat, there is over 50 inches of usable hip room in these vehicles.

Your letter states that the close proximity of the two inboard portions of the rear seat belt assemblies in the Le Car indicates that only two positions are intended by the manufacturer. The agency would give more credence to this factor if the inboard portions of the belt assemblies were on stiff, immovable cables (or similar design). With the current design, a person wishing to sit in the center position can easily move the belts out of the way, so the belts are not real impediments to use of the center position.

In answer to your ultimate question, the agency must conclude that the rear seat in the Le Car vehicle could qualify as having only two designated seating positions since the hip room is below 50 inches according to the technical measurement procedure specified in the standard. However, we think this is an extremely close case since there is over 48 inches of hip room even between the wheel wells and greater than 50 inches of hip room if the measurement is made mid-way the seat cushion. Therefore, we strongly urge Renault to modify its seat design or to add a third set of belts in this vehicle model. As noted in the letter to Toyota, if manufacturers do not voluntarily comply with the clear intent of the definition of "designated seating position", the agency may find it necessary to modify the measurement technique that is currently specified.

Sincerely,

ATTACH.

RENAULT USA

ENGINEERING & PLANNING GROUP.

March 3, 1980

Ralph Hitchcock, Chief -- Crashworthiness Division, National Highway Traffic Safety Administration

Dear Mr. Hitchcock:

Renault hereby requests a confirmation of its interpretation of the designated seating position definition contained in 49 CFR @ 571.3 to the effect that it would require two such seating positions in the rear seat of the Renault Le Car vehicle.

You will recall that we brought a 1980 Renault Le Car to NHTSA in December for examination by you and others of your office as well as representatives from Enforcement and Chief Counsel.

The rear seat width of this vehicle, a two-door hatchback with a folding rear seat, is 48.2-inches measured in accordance with SAE J1100(a). This 48.2-inch dimension includes the wheel wells, which protrude slightly into the seating area.

Renault's intention that the rear seat be limited to two designated seating positions is indicated, among other things, by the fact that the short inboard seat belts for the left and right seated passengers are located adjacent to one another.

Sincerely yours,

Francois Louis -- Governmental Affairs

ID: nht80-1.48

DATE: 04/10/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Whitley & Whitley, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. William N. Whitley Vice President, Whitley & Whitley, Inc. 20600 Chagrin Boulevard, Tower East Shaker Heights, Ohio 44122

Dear Mr. Whitley:

This responds to your February 8, 1980, letter asking whether the CarVan that you manufacture would be required to comply with Federal safety standards. The CarVan is designed to be mounted over the trunk of a car and weighs approximately 80 pounds.

The CarVan is considered a piece of motor vehicle equipment for purposes of compliance with the motor vehicle safety standards. Since it does not slide into the cargo area of a truck, however, it would not be considered a slide-in camper subject to Standard No. 126, Truck-Camper Loading. However, as a piece of equipment, it would be required to comply with Standard No. 205, Glazing Materials. I am enclosing an information sheet detailing where you can obtain a complete copy of all motor vehicle safety standards.

The agency notes that the CarVan would be installed in such a location that it would obscure the rear lights of the vehicle upon which it is mounted. The agency considers this to be very dangerous and concludes that you should adopt a tail light system for the CarVan. The Federal safety standard for lighting is Standard No. 108. Without a tail light system, the agency concludes that the installation and use of your CarVan would constitute a safety related defect, and we would exercise our authority to require any such defect to be remedied. We note also that many States prohibit any device that covers the license plates.

The agency would like to take this opportunity to correct some misinformation that was supplied to you on May 4, 1978, when we responded to your previous request for information on a camper that was designed to be loaded in a car's trunk. In that letter, the agency stated that the camper would be required to comply with Standard No. 126. That statement is incorrect. Since your camper is designed for a passenger car and not a truck, it would not be required to comply with Standard No. 126. It would be subject to the other standards mentioned above for the CarVan. We regret any inconvenience our error may have caused you.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

February 8, 1980

U.S. Department of Transportation National Highway Traffic Safety Administration Washington, D.C. 20590

Attention: Administrator for Rulemaking

Dear Sir:

We are considering manufacturing the CarVan. The CarVan is described in the enclosed resume.

Please indicate how the CarVan will be classed and be regulated by the Federal Motor Vehicle Safety Standards. Please note the CarVan will not slide into the car trunk but will be supported over the trunk.

I am enclosing a copy of your response to my request on a larger but similar type unit.

Sincerely,

WHITLEY & WHITLEY, INC.

William N. Whitley Vice President

WNW:Cj

The CarVan is a new light weight (80 pound) foldable gas saving recreational vehicle (RV). The unit can be attached to a standard or compact automobile trunk and meet the minimal living needs of two adults without increasing the gas comsumption of the automobile. The CarVan provides safe, secure, private space for sleeping, resting, cooking, eating, changing clothes and can be used for all day sports activities, fishing, hunting, skiing, overnight recreational or business travel.

The CarVan will appear and function (without wheels) as an extension of the car. The dimensions of the CarVan in the up position provide sufficient room for comfortable sitting, sleeping and standing, but extend the length of the car by only two feet. The unit folds down for easy road travel. The rear view mirror and regular side view mirrors of the car are functional while driving with the CarVan attached. No additional driving skills are required. Standard size garages and parking spaces may be used for car storage with the CarVan attached.