ID: nht88-3.1

TYPE: INTERPRETATION-NHTSA

DATE: 08/11/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: JAY V. WRIGHT -- PAGE AVJET CORP.

TITLE: NONE

ATTACHMT: LETTER DATED 04/21/88, TO CHIEF COUNSEL NHTSA, FROM JAY V. WRIGHT, OCC - 1930

TEXT: Dear Mr. Wright:

This is in response to your letter of April 21, 1988, asking whether a vehicle produced by your company is a motor vehicle subject to the requirements of the Federal motor vehicle safety standards. This vehicle, referred to as a hydrant truck, consists of a chassis-cab with an equipment platform mounted on its rear. According to your letter, the platform would be equipped with accessories that allow the vehicle to be used to filter and meter aircraft fuels as fuel is pumped from airport storage tanks i nto aircraft.

Section 102(3) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391(3)) defines a "motor vehicle" as any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any veh icle operated exclusively on a rail or rails.

We have interpreted this language as follows. On the one hand, vehicles that are equipped with tracks or are otherwise incapable of highway travel are plainly not motor vehicles. Agricultural equipment, such as tractors, are not motor vehicles. In add ition, vehicles intended and sold solely for off-road use are not motor vehicles, even though they may be operationally capable of highway travel. Examples include airport runway vehicles.

On the other hand, vehicles that use the public roads on a necessary and recurring basis are motor vehicles. For instance, jeep-type utility vehicles are plainly motor vehicles, even though they are equipped with special features to permit off-road oper ation. We have found vehicles to be motor vehicles if their on-road use is substantial, even though these vehicles' predominant intended use is off-road. Further, if a vehicle is readily usable on the public roads and is in fact used on the public road s by a substantial number of vehicle owners, NHTSA has found that the

vehicle is a "motor vehicle." This finding was made in the case of dune buggies, regardless of the manufacturers' stated intent that the vehicles were to be used off-road only.

You stated in your letter that this vehicle is not "perceived as being moved over public roads or from airport to airport in its daily use." It appears that this vehicle is intended and sold solely for off-road use, even though the vehicle appears operat ionally capable of highway travel. Based on the information provided in your letter, we conclude that your company's "Hydrant Truck" does not appear to be a motor vehicle. However, we will reexamine this conclusion if we learn that, for example, the ve hicle is regularly being used on the public roads.

We note that if your vehicle ever came to be regarded as a motor vehicle, there are probably few changes that would have to be made to bring it into compliance with the Federal Motor Vehicle Safety Standards (FMVSS). NHTSA encourages (but cannot require ) you to make these changes. The chassis-cab used to produce the hydrant truck already has been certified by its manufacturer as an incomplete vehicle. Therefore, in order to achieve compliance, it is likely that few standards would require any changes by your company. One such standard is FMVSS 108, Lamps, reflective devices, and associated equipment. Additional changes might also be required if the weight added by the equipment platform exceeds any weight maxima specified by the chassis-cab manufa cturer in making his certification.

Sincerely,

ID: 16443.ztv

Mr. Adam Englund
VeloCity
3373 Calle del Sur
Carlsbad, CA 92009-8616

Dear Mr. Englund:

This is in reply to your letter of November 13, 1997. I am sorry that we did not receive your original letter of October 14. Nor did we receive the product brochure that the letter mentions is enclosed. However, we are able to answer your request for an interpretation on the basis of information in your letter.

Your client, the Electric Transportation Company ("ETC"), manufactures an electric power pack, the ETC Express, that is designed for installation on bicycles. You state that the bike must be pedaled to activate the motor and that "the pedal assist system will not operate on its own, in the absence of muscular effort . . . ." You have asked for an interpretation that the ETC Express is not a "motor vehicle" or "motor vehicle equipment" for purposes of the regulations of the National Highway Traffic Safety Administration.

I am pleased to confirm your request. Because of your background in powered bicycles you are well aware that we consider a bicycle with a motor to be a "motor vehicle" if the vehicle is able to travel on level ground propelled solely by the motor, without any muscular input by the operator, for the duration of the battery charge. On the other hand, if the motor only assists the operator, and cannot propel the bicycle without the muscular input of the operator, a bicycle with this type of power assist motor is not considered a "motor vehicle" subject to our jurisdiction. It is a "bicycle," subject to the regulations of the Consumer Product Safety Commission.

On the basis of your statement that "the pedal assist system will not operate on its own, in the absence of muscular effort," a bicycle equipped with the ETC Express would not be a "motorvehicle" as we have interpreted the term with respect to motorized bicycles. This means that the ETC Express would not be considered "motor vehicle equipment" either.

Sincerely,
John Womack
Acting Chief Counsel
ref:VSA
d.12/97

ID: 86-2.35

TYPE: INTERPRETATION-NHTSA

DATE: 04/23/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Don Black

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Don Black Director, U.S. Engineering Office Alfa Romeo, Inc. 250 Sylvan Avenue Englewood Cliffs, NJ 07632

Dear Mr. Black:

This responds to your letter to Mr. Barry Felrice, our Associate Administrator for Rulemaking, requesting an interpretation of Part 541, Federal Motor Vehicle Theft Prevention Standard. Specifically, you stated that Alfa Romeo plans to label its front and rear bumpers in the following locations. The front bumper would have a label attached to the bumper assembly in the area where it would not be visible if a front license plate was attached to the bumper. The rear bumper would have a label attached to the rear bumper in an area that will be covered by a plastic snap-in molding. This molding must be removed to remove the rear bumper from the vehicle. You asked whether these planned locations would satisfy the requirement of S541.5(d)(1)(iii) that the labels be "visible without further disassembly once the part has been removed from the vehicle." It is NHTSA's opinion that the locations specified for marking bumpers in your letter would satisfy the requirement of S541.5(d)(1)(iii).

Your planned location for labeling the front bumpers is in an area where those labels will be visible at the time the cars arrive at the dealer and will remain visible unless and until a front license plate is installed on the car. NHTSA must thus determine whether the possible need to remove a front license plate would result in labels in this location failing to satisfy the requirement that labels be placed so that they will be "visible without further disassembly once the part has been removed from the vehicle." It appears not to be necessary to remove the front license plate in order to remove the front bumper from your vehicles. Hence, one might conclude that such location would not satisfy this requirement.

However, the intent underlying this requirement was clearly set forth in the rulemaking proceeding that established Part 541. The preamble to the notice of proposed rulemaking contained the following sentence: "Both commenters agreed, however, that NHTSA's regulations should ensure that investigators will not have to conduct any additional dismantling (over and above what chop shops, parts dealers, or thieves have ordinarily done) to locate the identifier on parts removed from a vehicle." (Emphasis in original) 50 FR 19731, May 10, 1985. NHTSA believes that license plates are routinely removed from front bumpers by legitimate parts dealers prior to reselling the bumper. Law enforcement groups have assured us that license plates are removed from stolen bumpers, so that the stolen part cannot be traced to its rightful owner. In these circumstances, the agency has no reason to believe that labels for front bumpers that are covered by the front license plate will require investigators to conduct additional dismantling of the front bumpers. Accordingly, we conclude that labels on front bumpers that are clearly visible when the front license plate is removed satisfy the requirement that those labels be "visible without further disassembly once the part has been removed from the vehicle."

With respect to the rear bumpers, the situation is simpler. According to your letter, the plastic molding covering the labels must be removed to remove the bumper from the vehicle. Thus, the label would be visible without further disassembly once the bumper has been removed from the vehicle. As such, it would satisfy the requirement of S541.5(d)(l)(iii).

If you have any further questions or need more information on this subject, please do not hesitate to contact me.

Sincerely,

Erika Z. Jones Chief Counsel

Ref. #027 February 18, 1986

Mr. Barry Felrice Associate Administrator for Rulemaking U.S. Department of Transportation N.H.T.S.A. 400 Seventh Street, S.W. Washington, D.C. 20590

RE: Request for Interpretation - Part 531 F.M.V.T.P.S.

Dear Mr. Felrice:

The enclosed sketches depict Alfa Romeo's intended bumper markings.

Sketch "A" - Shows the front bumper assembly. The complete bumper is covered with a semi-rigid plastic to protect it against minor damages. The label is attached to the actual bumper which is an aluminum extrusion. The label is visible following vehicle manufacture and at any time the front plate is not installed. These are two obvious cases where no front plate is used:

a) In states where only a rear plate is used.

b) On stolen vehicles, where the plates are removed.

Sketch "B" - Is a cross section of the bumper itself, an aluminum extrusion. This is to be considered the permanent part of the bumper assembly, while the semi-rigid decorative/protective cover mentioned above is considered a "wear" or "aesthetic" part subject to replacement.

Sketch "C" - Depicts the rear bumper, also an aluminum extrusion covered by a semi-rigid facing as used on the front bumper. The label is located in a groove in the facing where the aluminum extrusion is exposed adjacent to the mounting bolts for the bumper structural extrusion.

Ref. #027 Mr. Barry Felrice N.H.T.S.A. February 18, 1986 Page two

The label and the bumper bolts are covered by a small plastic snap-in moulding. To remove the bumper, the moulding must be removed followed by removal of the bumper bolts. It is worthy to note that with this design there is no location on which to place a label on a permanent part of the bumper since it is covered by the semi-rigid facing, which is again a "disposable" part of the bumper assembly.

Sketch "D" - Is a vertical view of the horizontal section carrying the label. Here the snap-in moulding can be seen covering the bumper bolts.

Alfa Romeo's opinion is that, considering the bumper design, these locations meet the requirements of "VISIBILITY" for the actual bumper since the facing itself would not likely be a theft target. We hope that N.H.T.S.A. will concur with Alfa Romeo's choice of location.

Respectfully,

ALFA ROMEO, INC.

Don Black Director, U.S. Engineering Office

DB/as

Enclosure

cc: B. McLauglin - N.H.T.S.A. Fogliata - Dires Sego Guelfi - Tires Carr Francioni - Marketing Prodotto M. Kole - ARI T. Tooley - ARI

ID: Lorenz.2

ID: Lorenz2

ID: nht90-1.83

TYPE: INTERPRETATION-NHTSA

DATE: 03/23/90

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TO: TILMAN SPINGLER -- ROBERT BOSCH GMBH

TITLE: NONE

ATTACHMT: LETTER DATED 2-13-90 TO TAYLOR FROM RICH VAN IDERSTINE, NHTSA, ATTACHED [43880]; ALSO ATTACHED TELEFAX TO RICHARD VAN IDERSTINE, NHTSA, FROM T. SPINGLER, ROBERT BOSCH GMBH, DATED 1-30-90.

TEXT: This is in reply to your FAX to Richard Van Iderstine of this agency, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.

Your first question is:

1) To turn the adjusting screws of a HB-2 headlamp it will be necessary to remove two snap on covers without the use of any tool. Will this be legal?

Section S7.7.2 requires a headlamp to be installed with a mounting and aiming mechanism that allows aim inspection and adjustment, "and is accessible for those uses without removal of any vehicle parts, except for protective covers removable without the use of tools." The section is not directed to the number of covers, only the ease of removal for the specified purposes. Therefore, the use of two snap on covers is not prohibited by Standard No. 108.

Your second question is:

2) A combination of HB2-headlight (low + high beam) and auxiliary driving beam in one unit shall be equipped with only vertical adjusting screws for the driving beam. The beam pattern will be so wide that even bulbs with extreme tolerances will allow to meet all photometric requirements without horizontal adjustment. Will this be legal?

Under section S7.7.2, the aiming mechanism of a headlamp must allow for adjustment of both horizontal and vertical aim. Thus, the portion of the lamp that provides the lower and upper beam must have both horizontal and vertical aiming screws, and the he adlamp would not comply with S7.7.2 if either aiming screw is lacking. For that part of the same headlamp that is a driving beam and which is therefore not regulated by Standard No. 108, the manufacturer may provide any means of adjustment it wishes, as long as it does not impair the effectiveness of the aim of the upper and lower headlamp beam.

Your final question is:

3) When will the 9007 bulb be legal? Date of final rule?

According to the plans of this agency, further action on the 9007 (proposed to be known as HB5) is expected in May 1990.

I hope that this responds to your questions.

ID: 7968

Mr. Mike Love
Manager, Compliance
Porsche Cars North America, Inc.
P. O. Box 30911
Reno, Nevada 89520-3911

Dear Mr. Love:

This responds to your request that NHTSA determine that a proposed modification to a previously approved antitheft device on the Porsche 911 car line constitutes a de minimis change to the device. The change is proposed to be made on only one model in the 911 line and to be effective beginning with the 1994 model year (MY). As explained below, the agency concludes that the proposed change to the antitheft device is not a de minimis change.

As you are aware, in a Federal Register notice of June 2, 1989 (54 FR 23727), NHTSA determined that the antitheft device, to be placed as standard equipment on the MY 1990 Porsche 911 car line, was likely to be as effective as parts marking. Subsequently, by letter dated May 31, 1990, the agency concluded that proposed changes to the antitheft device in the MY 1991 Porsche 911 car line were de minimis changes. The primary change for the 1991 model year was that the interior light control units were to be integrated with the alarm control unit and central locking system. The latter two components were already integrated.

For the following reasons, NHTSA concludes that the proposed change to the antitheft device for the 1994 model year is not de minimis. In reaching this conclusion, we looked primarily at the anti-theft system on which the exemption was originally based. Under the original system, locking one door would automatically lock all doors, as well as arm the alarm system. Under the proposed change, locking one door with the key would no longer automatically lock all doors, but would still arm the alarm system.

This is not an insignificant change like the substitution of new components for old components, each serving the same function. Nor does the change involve adding a feature making an exempted antitheft device even more effective. The change in question lessens the likelihood that all doors of a car will be locked, thus easing a thief's access to the passenger compartment. A thief may easily open the unlocked door, providing an opportunity to attempt to shut off the alarm system (since both the alarm control unit and the power lines from the battery to the alarm system are inside the vehicle) and to circumvent the engine disabling system. If the thief successfully overcomes these systems, theft of the entire vehicle or its parts is facilitated.

Once inside the vehicle, a thief may open the hood by a release in the vehicle interior, thereby gaining access to the storage space under the hood. Since the battery for the Porsche 911 is also located in the front hood compartment of the vehicle, access to the battery also makes it easier for a thief to attempt to shut off the alarm system and engine disabling system, again facilitating theft of the entire vehicle or its parts.

Because the same aspects of performance (i.e., the central door locking system that automatically locked all doors, making access to the vehicle interior and hood release more difficult), are not provided in the proposed device, resulting in the possibility of the vehicle's increased vulnerability to being stolen in whole, or to have its parts stolen, this agency concludes that Porsche's proposed modification to the antitheft device in one model in the MY 1994 911 car line is not a de minimis change.

If Porsche wishes to place its proposed antitheft device on the 911 car line, it must formally file a petition with NHTSA pursuant to 49 CFR 543.9(c)(2). Please note that the petition for a modification must provide the same information for the modified device as is required under 543.6 for a new device. This includes the statement in 543.6(a)(1) that the antitheft device will be installed as standard equipment on all cars in the line for which an exemption is sought.

Since the modification planned by Porsche would result in one model within the car line lacking a feature found on the anti- theft systems of other models, the agency would determine in the following manner whether the car line continued to merit exemption. It would regard the system of the one model as the system of the car line as a whole and assess whether that system would be as effective in preventing theft as parts marking. The additional feature on the other models within the car line, i.e., the central locking system, would be regarded as an addition to the standard equipment system and would not have any bearing upon the exemptability of the car line. NHTSA notes that this same approach would not be taken if the system to be installed on a single model within a car line could not be regarded as a stripped down version of the system on the other models. In that case, there would be no standard equipment version of the system and the car line would not be eligible for an exemption.

If you have any questions, please contact Ms. Barbara A. Gray, Chief, Motor Vehicle Theft Division, Office of Market Incentives, Office of Rulemaking, NHTSA, at this address or by telephone at (202) 366-1740.

Sincerely,

Barry Felrice Associate Administrator for Rulemaking

ref:543 d.12/1/92

ID: 2863yy

Mr. Louis F. Wilson
Instant Traffic Lights
2580 W. Venice Boulevard
Los Angeles, CA 90019

Dear Mr. Wilson:

This is in reply to your letter of February 20, 1991, with respect to the acceptability under Federal law of your product, the "Instant Traffic Light. I regret that we do not appear to have a record of your earlier letters to the agency on this subject.

The "Instant Traffic Light" is a four-section unit intended to perform three functions, each indicated by a different color. A green light appears when the accelerator is applied, an amber light when the accelerator is released, and a red light when the brakes are applied. The lamp's shipping carton shows the unit mounted on the rear parcel shelf behind the rear window. The text on the carton says that the lamp is easy to assemble. You have asked whether the product meets Standard No. l08, whether it would be "legal" in the U.S. "and her territories", and whether the product could replace, or be an option to, the requirements of Standard No. 108 for the center high-mounted stop lamp. Finally, of the l6 States that have responded to your inquiry, an equal number (six) have indicated that the lamp is and is not acceptable to them, while the remaining four "said they will follow the Federal requirement."

Standard No. l08 does not permit the center high-mounted stop lamp to be combined with any other lamp. This means that your product could not be used as original equipment on a passenger car, whether as standard equipment or as an option, or marketed and sold as replacement equipment for a center lamp on a passenger car that was originally equipped with it. However, Standard No. l08 does not apply to the "Instant Traffic Light" if it is marketed or sold exclusively for use on passenger cars that were not originally required to be manufactured with the center stop lamp, i.e., those cars that were manufactured before September 1, l985. Under this circumstance, the question of the legality of use of the device is to be determined by the laws of the individual States. The "territories" are "States" for purposes of this discussion. Since there is no legal prohibition under Federal law for installation of your lamp only on older passenger cars, we presume that the four States that reserved their decision would permit it on pre - l985 vehicles registered and/or operating within their borders.

We are aware that, nevertheless, there may be some owner interest in replacing original equipment center stop lamps with your product. We would like to advise that such replacement would be a violation of the National Traffic and Motor Vehicle Safety Act, if performed by a manufacturer, distributor, dealer, or motor vehicle repair business. There is no such restriction upon a vehicle owner who performs the replacement of the lamp himself.

I hope that this responds to your questions.

Sincerely,

Paul Jackson Rice Chief Counsel

/ref:l08 d:3/8/9l

ID: nht95-4.25

TYPE: INTERPRETATION-NHTSA

DATE: September 19, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: T. J. Sommer -- President, White Bear Sales, Inc.

TITLE: NONE

ATTACHMT: ATTACHED TO 7/28/95 LETTER FROM T. J. SOMMER TO TAYLOR VINSON (OCC 11121)

TEXT: Dear Mr. Sommer:

This is in reply to your FAX of July 28, 1995, to Taylor Vinson of this Office.

You report that Chicago's police department is using four-wheeled all terrain vehicles (ATVs) for patrol work in the downtown area, and that they have been licensed by Illinois for on-road use. You believe that the vehicles are illegal to use on the str eets and that city employees are at risk. You have been asked by the director of Chicago's fleet "to compile all federal definitions and statutes which apply to the quad runners, regarding classification, certification, and compliance for street use." Y ou have asked for our assistance.

I note first that while Federal law regulates the manufacture and sale of new motor vehicles, the individual States establish their own requirements for the licensing of motor vehicles. Therefore, the question of whether the ATVs may legally be used on the road is a matter of Illinois law rather than Federal law.

Your letter does, however, raise the issue of whether the manufacture and/or sale of the ATVs was consistent with Federal law. We do not have specific information about the ATVs at issue; however, I can provide general information about how Federal law applies in this area.

By way of background information, Chapter 301 of Title 49 of the U.S. Code authorizes NHTSA to issue safety standards for new motor vehicles and new motor vehicle equipment. All motor vehicles and items of motor vehicle equipment manufactured for sale i n the United States must comply with all applicable safety standards set forth in 49 CFR Part 571.

The issue of whether the ATVs were required to comply with the Federal motor vehicle safety standards is dependent on whether they are considered "motor vehicles." I have enclosed several interpretation letters which address the criteria which NHTSA appl ies in determining whether a vehicle with on and off-road capability is a motor vehicle (addressed to Mr. Matthew Plache, dated December 3, 1991; Mr. Hiroshi Kato, dated October 31, 1988; Mr. Wayne Kirby, dated February 8, 1983; and Mr. Leonard Fink, dat ed March 25, 1982). If an ATV is a motor vehicle, it must be certified to comply with all applicable safety standards.

If, after reviewing this information, you believe that a violation of Federal law may have occurred, you may wish to contact Mr. Luke Loy of NHTSA's Office of Vehicle Safety Compliance at (202) 366-5288. If you have further questions about the applicabi lity of our standards, please feel free to contact Mr. Taylor Vinson of my staff (202-366-5263).

ID: 1983-2.40

TYPE: INTERPRETATION-NHTSA

DATE: 08/08/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: C. B. Bright Motor Co.

TITLE: FMVSS INTERPRETATION

TEXT:

U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION Washington, D.C. 20590

August 8, 1983

Mr. C. B. Bright, Jr. C. B. Bright Motor Co. Route 1 Ashland, MS 38603

Dear Mr. Bright:

This is in reply to your letter of July 19, 1983, to Mr. Vinson of this office. You have asked whether you are violating any Federal standards or regulations by adding "right side steering, accelerator, brakes & turn signal controls to rural mail carriers delivery vehicles (cars, pickup, jeeps, etc.)." You have told us that you do not modify in any way the left hand side controls with which the vehicle was originally equipped.

Assuming that your modifications do not affect the performance of any of the systems with which the vehicle was equipped by its original manufacturer, your conversion operations would not be prohibited by the National Traffic and Motor Vehicle Safety Act. However, with respect to any new vehicle that you modify which has not yet reached its first purchaser for purposes other than resale, you are required to affix a label identifying you as the alterer and certifying that the vehicle as altered meets all applicable Federal motor vehicle safety standards. This is required by Title 49 Code of Federal Regulations, Section 567.7. I enclose a copy of Part 567 for your information.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

C. B. BRIGHT MOTOR CO. Ashland, Miss. 38603

July 19, 1983

MR. TAYLOR VINSON OFFICE OF CHIEF COUNCIL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION NUMBER 400 7th. ST. S.W. WASHINGTON, D.C. 20590

MR. TAYLOR:

IN REGARDS TO OUR TELEPHONE CONVERSATION ON OUR ADDING RIGHT SIDE STEERING, ACCELERATOR, BRAKE & TURN SIGNAL CONTROLS TO RURAL MAIL CARRIERS DELIVERY VEHICLES ( CARS, PICKUPS, JEEPS & ETC.).

WE DO NOT CHARGE UP, MODIFY OR TAKE OUT ANY OF THE FACTORY INSTALLED CONTROLLS THAT HAVE BEEN CERTIFIED BY THE FEDERAL GOVERNMENT. CONTROLS MEANING STEERING, BRAKE, ACCELERATOR AND TURN SIGNAL.

WE HAVE ADDED THESE DUAL CONTROLS TO MAIL CARRIER DELIVERY VEHICLES SINCE 1958 AND THE USE AND SAFETY HAVE BEEN PROVED BEYOND ANY DOUBT.

I WOULD LIKE TO KNOW IF WE VIOLATE ANY STANDARDS OR REGULATIONS WHEN WE ADD THE DUAL CONTROLS ( STEERING, BRAKE, ACCELERATOR AND TURN SIGNAL CONTROL FOR RIGHT SIDE USE OF VEHICLE.).

ENCLOSED IS A COPY OF A LETTER FROM THE NATIONAL PRESIDENT OF THE NATIONAL RURAL LETTER CARRIER'S ASSOCIATION.

I SINCERELY THANK YOU FOR THE KINDNESS AND CONSIDERATION YOU GAVE ME BY PHONE.

SINCERELY,

C. B. BRIGHT

NATIONAL RURAL LETTER CARRIERS ASSOCIATION

February 8, 1983 Mr. C. B. Bright Committeeman, Mississippi Rural Letter Carriers' Assn. Ashland, Mississippi 38603

Dear C. B.

This is in response to our telephone conversation concerning the dual controls which you manufacture and install on vehicles for rural carriers.

I advised you I would write you a letter relative to my own use of the dual controls. For the last several years I served on Route #1, Palestine, Arkansas. I used a vehicle equipped with the dual control system. That was during a period that ended in September, 1977. At that time, I assumed the duties of a Na-tional Officer and I have not carried a rural route since that time.

My own personal experience with the dual controls proved to be completely satisfactory, both from an operational and a safety standpoint. The steering was completely functional and the accelerator and brakes were also without fault.

******Letter not complete due to poor copy.