ID: nht79-1.7

DATE: 10/24/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: VDO-ARGO Instruments Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. H. A. Ritzenthaler VDO-ARGO Instruments Inc. 980 Brooke Road P.O. Box 2630 Winchester, Virginia 22601

Dear Mr. Ritzenthaler:

This is in response to your letter of January 25, 1979, in which you stated your interpretation of Federal Motor Vehicle Safety Standard 127, Speedometers and Odometers, and asked that we advise you if action taken in accordance with this interpretation would place your company in violation of the standard. This letter is to confirm that your interpretation is correct.

According to your interpretation of Safety Standard 127, those provisions which become effective for new motor vehicles on September l, 1979 and September 1, 1980 are not applicable to speedometers and replacement parts produced for use in motor vehicles manufactured before those dates. This is correct because Safety Standard 127 is a vehicle standard and an equipment standard which applies to passenger cars, multipurpose passenger vehicles, trucks, motorcycles, and buses manufactured after the standard's effective dates and to speedometer and odometers for use in such vehicles. (Section 3, Safety Standard 127).

Sincerely,

Frank Berndt Chief Counsel

U.S. Department of Transportation National Highway Traffic Safety Admin. 300 Seventh Street S.W. Washington, D.C. 20590 January 25, 1979

ATT: Mr. Richard B. Dyson, Acting Chief Counsel

Dear Mr. Dyson:

We are a manufacturer of automotive instruments, including speedometers. The changes required on speedometers for new cars after the effective dates September 1979 and September 1980 are clearly defined in Regulation 127, and our original equipment speedometers will be in compliance with this regulation.

We also have an obligation toward the automotive industry to supply original replacement parts for a period of ten years after manufacture of a particular vehicle model has ceased. These replacement parts for cars manufactured before the effective dates of Regulation 127 would, of course, not embody the changes called for in Regulation 127, nor does the regulation itself require such modifications in reference to replacement parts.

This is our interpretation of the applicability of Regulation 127. Should you feel that this interpretation would put us in violation of Regulation 127, please advise us accordingly.

Sincerely, VDO-ARGO INSTRUMENTS, INC.

H. A. Ritzenthaler Manager, Engineering

HAR/nf

ID: nht79-1.8

DATE: 12/05/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: R. Birch

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-3O

Mr. R. Birch Chief Constable P.O. Box 4 Leek Wootton Warwick, England CV35 8QB

Dear Mr. Birch:

This responds to your recent letter concerning a reflective film that is being applied to the windows of some vehicles in the United Kingdom. You ask whether regulations preventing the use of such film have been introduced in the United States.

At the current time, there are no Federal regulations that prohibit the use of reflective films such as you describe. The National Highway Traffic Safety Administration issues safety standards and regulations governing the manufacture of new motor vehicles and motor vehicle equipment. We have no authority, however, to regulate the use of motor vehicles, such as an owner applying reflective film to his car. Further, we have issued interpretations stating that reflective coated polyester films do not qualify as glazing materials and, therefore, do not come within the purview of our Safety Standard No. 205. This interpretation referred only to polyester film sold by itself. Glazing materials that have coated films that were applied by the glazing manufacturer are required to comply with the standard, including the light transmittance requirements.

The agency did receive a petition for rulemaking last year from the California Highway Patrol asking that reflective glazing materials be prohibited (glazing coated with reflective substances by the glazing manufacturer). While use of the reflective coating could reduce the ability of a driver to look through the glazing of vehicles in front of him or her and she the road and vehicles ahead, we denied the petition since we lacked data indicating that there is a safety problem created by the coating. If you have or know of any data indicating a safety problem, we would very much appreciate seeing the data. From a law enforcement viewpoint, the problem posed by the reflective coating is apparently more than theoretical, since officers cannot see inside a vehicle with coated glazing to the extent they deem necessary.

Sincerely,

Frank Berndt Chief Counsel

ID: nht79-1.9

DATE: 10/11/79

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood for F. Berndt; NHTSA

TO: Orient Glass, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. J. Ohmura Orient Glass, Inc. 445 South Figueroa Street Los Angeles, California 90071

Dear Mr. Ohmura:

This responds to your recent letter asking whether a bus bar extension on rear-window passenger car glazing would comply with Safety Standard No. 205. I assume from your letter that the bus bar is a defrosting template that is embedded in the glazing material.

Safety Standard No. 205, through the ANS Z26 standard that is incorporated by reference, requires glazing materials requisite for driving visibility in passenger cars to have a luminous transmittance of at least 70 percent (Test No. 2 in ANS Z26). This requirement would be applicable to rear-window glazing for passenger cars, since these windows are necessary for driving visibility. Rear-window glazing that contains a bus bar extension and electrical template wires would still have to comply with the 70-percent luminous transmittance requirement, when tested in accordance with Test No. 2. The .67-inch bus bar extension would not preclude compliance with this requirement, although it obviously has no luminous transmittance, if the remaining parts of the glazing meet the 70-percent requirement. However, if the electrical wires of the template are so numerous or located so near each other that a tested section of the glazing would not have a luminous transmittance of at least 70 percent, the rear window would not be in compliance with Safety Standard No. 205.

Sincerely,

Frank Berndt Chief Counsel

August 22, 1979.

U. S. Department of Transportation NHTSA Office of Standards Enforcement Washington, D. C. 20590 (Att: Mt. Frank Berndt)

Dear Mr. Berndt,

We have been referred to you by Mr. Heath, of The California Highway Patrol for approval of bus bar extension on rear window auto glass.

As shown in the enclosed attachments this particular bus bar extends 0.67 inch from the edge of the AS-2 approved Tempered Auto Glass. We need written confirmation that this bus bar design complies with your standard, FMVSS 205.

Please let us know if there are any other requirements for approval.

Thank you for your prompt attention to this request.

Thank you.

ORIENT GLASS, INC.

J. Ohmura

JO/mw

August 15, 1979

File No.: 62.A661.A4381

Mr. J. Omura Orient Glass, Inc. 445 S. Figueroa Street Suite 2430 Los Angeles, CA 90071

Dear Mr. Omura:

This is to confirm your telephone conversation of August 2 with Mr. Max Mizoguchi of this office regarding the location of the electrical bus bar in glazing materials.

Original equipment safety glazing meeting the requirements established by the National Highway Traffic Safety Administration is acceptable for sale in California. If you feel that your design may not comply with FMVSS 205, you may wish to contact their legal department to seek clarification. Questions should be directed to:

U. S. Department of Transportation NHTSA Office of Standards Enforcement Attention Mr. Frank Berndt Washington, D.C. 20590

Please supply us with a copy of all correspondence on this subject.

We trust this information will be helpful to you.

Very truly yours,

W. W. HEATH, Chief Engineer Acting Commander Commercial and Technical Services Section

ID: nht87-3.33

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/87 EST

FROM: REGIONAL TRANSPORTATION DISTRICT

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12/09/88 FROM ERIKA Z. JONES -- NHTSA TO JACK MCCROSKEY AND GLENDA SWANSON LYLE, REDBOOK A33, STANDARD 119; LETTER DATED 09/13/88 FROM JACK MCCROSKEY AND GLENDA SWANSON LYLE TO LARRY COOK -- NHTSA, OCC 2539; LETTER DATE D 08/26/88 FROM R. E. MORGAN TO MARVIN ORNES; LETTER DATED 09/09/87 FROM RE MORGAN TO R. ROGERS RE GOODYEAR MILEAGE TIRES, REF BRUCE RUMAGE PHONE CALL

TEXT: SPECIAL SERVICES

Fares can be paid in cash (exact amounts only), with tokens, tickets or a monthly pass. Peak hours are weekdays 6 a.m. to 9 a.m. and 4 p.m. to 6 p.m. All other times are off-peak hours. Transfers are free and are issued upon boarding. Riders must p ay the difference in fare when transferring to a more expensive level of service. Peak Off-Peak Elderly & Handicapped Off-Peak Circulator $ .50 $ .50 $ .10 Local .75 .50 .10 Express 1.25 1.25 .10 Regional 2.00 2.00 .10 Boulder City .50 .50 .10 Longmont City .25 .25 .10 Tokens Tokens are available in 25 cent and 75 cent denominations from all RTD sales outlets. The 25 cent tokens are also available from Albertsons, King Soopers and Safeway stores. 10-Ride Books of 10 single trip coupons are avail-Ticket Books able at 10 percent discount for Regional, Express and Local service at all RTD sales outlets. The coupons are good during the calendar year in which they are purchased. Monthly RTD monthly passes are valid throughout Passes the stated month for which they are purchased. The passes are good for unlimited rides on the level of service purchased, less expensive levels of service, or as a credit toward more expensive levels of service. The passes offer a 15 percent discount over cash fares and can be valid for extra benefits too, such as discounts from local merchants or for special events. Passes are available at any RTD sales outlet and at Safeway and King Soopers stores. Passes also can be obtained through the mail or by phone (777-8893). Some individuals are eligible for additional pass discounts, including youths 18 and under, students of any age at accredited schools, senior citizens 65 and over and disabled individuals. The reduced rate passes are available from RTD sales offices or through the mail.

DIRECTORS

RTD offers a variety of special services, including those for the elderly, handicapped and students. More than 77 percent of the District's fleet is fully accessible to handicapped persons in wheelchairs. RTD also offers the handyRide program, a cur b-to-curb subscription service to meet the needs of those more severely disabled individuals who cannot use regular accessible service.

The popular seniorRide gives thousands of elderly persons the opportunity to participate in more than 300 social, educational and recreational events during the year. A shopper service provides midday trips to shopping centers for the elderly and han dicapped. For information call 778-3503.

Persons ages 18 and under are offered independence during the summer months with the Summer Youth Pass. For just $ 7 a month, the pass gives unlimited rides on all Local, Limited and Circulator routes and may also be good for discounts at selected ar ea merchants.

RTD also offers BroncoRide and BuffaloRide to get fans directly to Denver Bronco and University of Colorado (Boulder) home football games. The Mall The 16th Street Mall, built by RTD, was officially opened in October 1982. It is anchored at both ends by transit stations, linked by the free Mall shuttles. A fleet of 26 shuttle buses operates along the mile- long mall, and carried 11.9 million people in 1986. District A Jack McCrosky Downtown & Central DenverDistrict B Glenda Swanson Lyle, Northeast Denver District C Henry L. Solano, North Denver District D Michael J. Garcia, Southwest Denver District E Bob Jacobsen, Southeast Denver District F Mary Duty, Aurora District G Richard P. Karma, Second Vice Chairman Arapahoe/Douglas CountiesDistrict H J. Bear Baker, Secretary Arapahoe CountyDistrict I Bill Womack, First Vice Chairman East Boulder/Adams CountiesDistrict J Kevin Sampson, Northwest Adams County District K Robert June, East Adams County District L Thomas G. Thomas North Jefferson CountyDistrict M Helen W. Steele, Treasurer Central Jefferson CountyDistrict N Stephen C. Millard, South Jefferson County District O Roger Cracraft, Chairman West Boulder County GeneralChester E. Colby Manager

(PHOTOGRAPH OMITTED)

OPERATING STATISTICS 1985-1987

The Regional Transportation District is a public agency created in 1969 by the Colorado General Assembly to develop, operate and maintain a mass transportation system for the benefit of the people in RTD's six-county service area.

The service area includes all of Boulder, Denver and Jefferson counties, and the urban portions of Adams, Arapahoe and Douglas counties.

The District is governed by a 15-member board of directors elected for four-year terms. Route/ Telephone Information Center, open 5 a.m. Schedule to 10 p.m. weekdays; 7 a.m. to 10 p.m.Information weekends and holidays. 778-6000 Denver Metro Information 777-3343 Boulder Information 1-800- Calls to TIC from outside Denver Metro 223-1565 dialing area 778-1034 TDD Information (for persons with speech or hearing impairments) Customer For information not related to routes and Service schedules. Monday through Friday, 8 a.m. to 5 p.m.573-2343 District-wide Customer Service 573-2202 TDD (for persons with speech or hearing impairments) 1,843,000 Population within six-county service area 35 Cities and towns served 2,304 Square miles in service area 26,830,314 Current annualized route service miles 2,278 Miles of routes (1986) 8,900 Bus stops 149 Total number of routes 47 Local 54 Express 16 Regional 6 Circulator (including mall) 10 Boulder City 5 Longmont City 9 Limited 2 Paratransit 170,000 Estimated 1987 average weekday boardings (includes approximately 40,000 Mall Shuttle boardings) 51,500,000 Estimated 1987 annual boardings (includes approximately 11,500,000 on Mall Shuttle) 91,813 Daily miles operated (1987 average weekday) 7,535,325 Diesel fuel consumption (1986 gallons) 759 Total active buses in fleet 588 Wheelchair lift-equipped buses 5.3 years Average fleet age 38 Park-n-Ride facilities 598 Peak-hour buses required (October 1987) 2,055 Total number of employees (1987 Adopted Budget) 419 Salaried employees 1,636 Represented employees (including approximately 110 part-time bus operators) 1987 1986 1985 Adopted Actual Actual Budget .6 of one $ 79,500,000 $ 77,941,000 $ 78,851,000percent general sales tax Transit Fares $ 18,000,000 $ 17,423,000 $ 17,927,000 Federal $ 30,231,000 $ 32,569,000 $ 20,557,000Grants Investment $ 8,679,000 $ 8,419,000 $ 8,689,000Income & Other Debt $ 0 $ 19,485,000 $ 1,275,000Financing From 1986 fund balance carryover: Federal $ 11,797,000 $ 0 $ 0Capital Grants Local Funds $ 11,219,000 $ 0 $ 0 Total $ 159,426,000 $ 155,837,000 $ 127,299,000 Operations & $ 100,122,000 $ 104,959,000 $ 103,011,000Administration Capital $ 63,688,000 $ 39,749,000 $ 25,381,000 Total $ 163,810,000 $ 144,708,000 $ 128,392,000 Ending $ 51,479,000 $ 51,269,000 $ 58,377,000accumulated revenues over expenditures

ID: nht87-3.34

TYPE: INTERPRETATION-NHTSA

DATE: 12/03/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: M. Iwase, Manager, Technical Administration Dept. Koito Mfg. Co., Ltd.

TITLE: FMVSS INTERPRETATION

ATTACHMT: 7/23/87 letter from Erika Z. Jones to M. Iwase (Std. 108)

TEXT:

Mr. M. Iwase, Manager Technical Administration Dept. Koito Mfg. co., Ltd. Shizuoka Works 500, Kitawaki Shimuzu-shi, Shizuoka-ken JAPAN

This is in reply to your letter of September 15, 1987, with further reference to features of a 60 degree slant replaceable bulb headlamp presently being developed by Koito. You have explained that the aiming pads for the new system will be installed on t he aiming adapter, rather than the headlamp lens, and have asked for confirmation that this is "not illegal" under Motor Vehicle Safety Standard No. 108.

As you noted in your letter, paragraph S4.1.1.36(a) (2) specifically requires the exterior face of each replaceable bulb headlamp lens to have three aiming pads. The agency has no specifications for the design of aiming adapters, and a headlamp without a iming pads would be one that is not designed to conform to the standard.

The agency is examining concepts for aiming methods for other than mechanical aim, but no amendments to Standard No. 108 are contemplated that would permit or require aiming pads to be on aiming adapters.

Sincerely, Erika Z. Jones Chief Counsel

Air-Mail Ms. Erica Z. Jones Chief Counsel National Highway Traffic Safety Admin. 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. E. Z. Jones:

We would like to further ask you the following question of headlamp aiming adaptor in connection with your kind advice mentioned in your letter of July 23, l987 replying to our letter of March 24, l987. (Refer to the attached.)

RE = 1 ) Aiming Adaptor for 60 " Slant Bulb Replaceable Headlamp

As shown below, instead of being installed, on the lens of headlamps, aiming bosses are installed on the surface of the special adaptor which is to be equipped onto each vehicle so that mechanical aiming can be performed, by use of the headlamp aimer " s pecified SAE J602C.

Of course, the special adaptor is so designed that it can be surely attached onto the proper design position of headlamps.

The aiming bosses and markings, which are applied to 54. 1. 1.36 (a) (2)& (3) of FMVSS No. 108, are placed on the surface of the special adaptor.

(INSERT GRAPHICS)

Attn: Ms. Erica Z. Jones Date: Sept. 15, 1987 Page: 2 / 3

Question:

We believe that the aiming boss installation as abovementioned can be applied to FMVSS NO. 108 and not illegal under FMVSS NO. 108. We would like you to confirm whether our interpretation is correct or not.

Aiming pads are specified in 54.1. 1.36 (a) (2) of FMVSS NO. 108 as follows;

"The exterior face of each replaceable bulb headlamp lens shall have three pads which meet the requirements of Figure 4, Dimensional Specifications for Location of Aiming Pads on Replaceable Bulb Headlamp Units .. ."

However, for all this prescription, we can not find it necessary that aiming pads shall be placed on the lens of headlamps which can be aimed by the use of the adaptor equipped onto each vehicle, because the special adaptor can be designed regardless of lens bosses so as to be surely attached onto the proper design position of headlamps in any way, we think.

And it is not only useless but also impractical that the specified aiming bosses are placed onto the lens of headlamps which slant up to about 60o in vertical and horizontal, because the projection of the aiming bosses becomes higher according to the len s slant inevitably.

(INSERT GRAPHICS)

Attn: Ms. Erica Z. Jones Date: Sept. 15, 1987 Page: 3 / 3

Upon our consideration of the abovementioned matter, it should not be required that aiming bosses shall be placed on the lens of headlamps which are aimed by use of the special adaptor equipped onto each vehicle.

Upon your review, your prompt reply to this matter would be greatly appreciated.

Very truly yours, M. Iwase Manager Technical Administration Dept. Koito Mfg. Co., Ltd. Shizuoka Works

See 7/23/87 letter from Erika Z. Jones to M. Iwase.

ID: nht87-3.35

TYPE: INTERPRETATION-NHTSA

DATE: 12/03/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Frank Miller -- Gerry Baby Products

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Frank Miller Gerry Baby Products 12520 Grant Drive Denver, CO 80233

This responds to your September 25, 1987 letter to Mr. Val Radovich of NHTSA's Office of Vehicle Safety Standards and your October 19, 1987 letter to my office concerning paragraph S4.2.1 of Safety Standard No. 302, Flammability of Interior Materials.

You ask whether the thread that is used in the manufacture of a seat cushion is tested as part of the component. The answer is yes. In a March 10, 1978 interpretation of Standard No. 302, NHTSA recognized that stitching that does not adhere at every poin t of contact should be tested separately under S4.2.1. However, the agency also determined that, from the standpoint of practicality, the stitching cannot be tested separately in the prescribed manner. NHTSA thus concluded that stitching will be tested a s part of the material itself.

Please contact us if you have further questions.

Sincerely,

Erika Z. Jones Chief Counsel

September 25, 1987

To: Mr. Val Radovich Office of Vehicle Safety Standards National Highway Traffic Safety Admin. 400 Seventh Street, S.W. Washington, D.C. 20590

From: Frank Miller Gerry Baby Products 12520 Grant Drive Denver, CO 80233

Dear Sir:

This inquiry is in regards to the flame retardancy requirements of FMVSS 302, specifically S4.2.1. A question has been brought up about the thread that is used in the manufacture of the seat cushion.

Is the thread considered to be part of the composite?

Thank you for your time.

Sincerely,

Frank Miller Quality Engineer

October 19, 1987

Office of Chief Counsel NHTSA 400 Seventh St. S.W. Washington, D.C. 20590

Dear Sir/Madam:

To satisfy our specifications we need written legal interpretation of the term "composite" as used in FMVSS 302.

Our feeling is that as long as the sewn seat meets the requirements, the thread and/or binding does not have to meet the requirements if tested separately. We feel this way because the thread and binding in the Gerry Guardian Car Seat adheres to the seat cushion at every point of contact.

Your response to this matter will be greatly appreciated.

Sincerely,

Frank Miller Quality Engineer

ID: nht87-3.36

TYPE: INTERPRETATION-NHTSA

DATE: 12/04/87

FROM: WARD W REESER -- PROJECT ENGINEER ELECTRICAL SYSTEMS, CATERPILLAR INCORPORATION

TO: TAYLOR VINSON -- NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/08/88 TO WARD W. REESER FROM ERIKA Z. JONES; REDBOOK A32(2) VSA 102

TEXT: Dear Mr. Vinson:

Caterpillar Inc. has initiated a program to review all of the lighting used on the entire Caterpillar product line throughout the world. We are attempting to standardize wherever possible those devices used in the U.S. and Canada, Europe, Japan, and Aus tralia.

As you are aware, this line of construction and industrial equipment is basically for off-highway use. There are occasional uses on the highway for such equipment as motor graders, but obviously none of this equipment is designed for normal highway use or for the transportation of people.

Specifically, we need to know if there are any lighting devices required under Federal Motor Vehicle Safety Standard No. 108 for the line of products shown in the attached brochure. An early reply would be appreciated.

Sincerely,

[CATERPILLAR INCORPORATION BROCHURE OMITTED]

ID: nht87-3.37

TYPE: INTERPRETATION-NHTSA

DATE: 12/04/87

FROM: PAUL L. PETERSCHMIDT -- DIRECTOR, BIOMASS RESEARCH UNIVERSITY OF IOWA

TO: GEORGE PARKER -- ASSISTANT ADMINISTRATOR FOR ENFORCEMENT DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/24/89 FROM ERIKA Z. JONES -- NHTSA TO KEITH E. MADDEN, REDBOOK A33(2), CUSTOM REGULATIONS; LETTER DATED 02/03/89 FROM KENNETH E. MADDEN TO ERIKA Z. JONES -- NHTSA, OCC 3106

TEXT: Dear Mr. Parker:

This letter is in regard to importation of "Motor Vehicles and Motor Vehicle Equipment Subject to Federal Motor Vehicle Safety Standards" (P.L. 89-563 Sects. 108 and 114, 19 C.F.R. 12.80) and related to DOT Form HS 7, Item 7.

The vehicles involved in this request for importation would be classified (under Item 7) as being imported solely for the purpose of test and experiment. The purpose of this letter is to explain the objectives of our research program and the need for th is undertaking.

BACKGROUND

Brazil has in the order of 1.3 million vehicles on the road which are fueled by "neat" ethanol, which is also referred to as hydrous ethanol. The hydrous azeotropic product of ethanol distillation has to be dehydrated to the anhydrous form to be involve d in blending operations with gasoline in this country. The hydrous ethanol fuel for the Brazilian vehicles has a typical analysis of 95% ethanol and 5% water. Today the vast majority of the new over the road passenger vehicles and light trucks in Braz il are ethanol dedicated designs. The use of ethanol as the only fuel was inaugerated about ten years ago, and prompted by the lack of natural petroleum reserves in Brazil. The production of significant numbers of over the road passenger vehicles was in augerated in the early part of this decade, and the production rate has been increasing ever since. About 90% of Ford Brazil's over the road passenger car production models are ethanol fueled vehicles.

During this period (the decade of the 1980's) little, if anything has been done to evaluate these vehicles in the U.S. in terms of performance, economics, exhaust gas composition, emission controls, fuel economy-ambient problems, durability, the material s of construction to accomodate the ethanol fuel, maintenance, power trained design, fuel composition (there are no denaturants used in Brazil), cold weather starting, hot weather Reed vapor pressure problems, etc.

To our knowledge there has been practically no importation of these over the road ethanol vehicles primarily because of a lack of any comprehensive testing programs, and the lack of import approval by the EPA and the DOT. Also the provisions for either re-exporting the vehicles or destroying the vehicles after one year was an obvious deterrent. It is also significant that in the recent "Fuel Ethanol Cost-Effective Study" which was prepared by the National Advisory Panel on Cost Effectiveness of Fuel E thanol Production, published in November of 1987, the accompanying bibliography cited ten pages of references (125) and only one reference was a reference to Brazilian technology in ethanol vehicles. This one reference had to do with "Automotive Use of Alcohol in Brazil and Air Pollution Related Aspects. SAE Technical Paper 850390, February 1985." This University has been involved in research on the production economics of ethanol and utilization throughout this decade. In 1983 we were provided with a Ford-Brazilian designed prototype tractor (which was a modified 4600 design), one of seven in the world, which was ethanol fueled. We tested the unit under field operating conditions for approximately 20 months. The unit was considered a "dedicated" ethanol design and brought into this country by Ford Tractor operations at Troy, Michigan. The unit was equipped with a number of design features which enabled it to perform effectively in cold weather conditions. The tractor was placed on a research f arm operated by Pioneer Hi-Bred International near Iowa City and was used for farm tasks ranging from a feedlot operation through forage operation and silo filling.

The unit was heavily instrumented and a large body of information collected involving cold and hot weather operating characteristics, and its general economy of operation was compared to conventional diesel fueled units that were performing similar tasks . Because of the prototype nature of the test unit, data was not published as Ford Tractor Operations was considering the potential sale of the design in this country.

The unit did go into production in Brazil and eight production prototypes are in an evaluation program by the Illinois DOT.

CURRENT SITUATION

The units we wish to import will be either the F-100 Ford pickup (upon which you already have specifications) or the F-1000, which is about 3.6 liters and somewhat comparable to the Ford "Ranger" produced in this country. It should be pointed out tha t Ford Brazil has, as of the first of July merged with Volkswagen in Brazil. They have formed a company named "Auto-Latino". The company does produce some gasoline fueled vehicles that are imported into this country under the name of the Volkswagon Fox . The manager of Volkswagen altered the executive responsibilities of several of the people with whom we had maintained liaison at Ford Brazil. It should also be pointed out that we made our original inquiries to Ford Brazil over two years ago regardin g the importation of their over the road vehicles and obtained the necessary clearances that we needed from that end but we did not follow through on our programming of a test project because of lack of funds. The following is the program that we will m anage in the testing of the three vehicles we request approval to import.

OBJECTIVES

The overall efficiency of the dedicated ethanol fueled vehicles has been continually improving -- to a point where a 3 to 4% increase in efficiency would balance out the difference in BTU values of gasoline versus ethanol. (Gasoline being approximately 110,000 BTU and ethanol being approximately 85,000 BTU). * The dedicated ethanol spark injection engine had traditionally been more fuel efficient than its gasoline counterpart.

* per U.S. Gallon

The objective of this test is three-fold:

1. To determine the efficiency of the Brazilian units and what improvements might be made by the use of fuel injection, and alternate fuel composition.

2. To determine the operational economics of the Brazilian vehicles as compared to similar gasoline fueled vehicles, using current gasoline prices and current ethanol production costs.

3. Evaluate the ambient effects (particularly cold weather) on vehicle operation (particularly engine starting) and classify them as to degrees of difficulty and outline corrective measures.

4. Evaluate alternate fuel compositions (i.e. use of detergents as a denaturant).

5. Evaluate emissions and determine the need (if any) for control procedures.

6. Evaluate the procedures for fuel handling and establishing compliance with BATF.

7. Evaluate potential customer acceptance.

8. Set a time frame (if possible) for on going research or commercial development.

TEST PROCEDURES

The units would be tested in an agricultural environment for a number of reasons, among which is to minimize the problems of fuel handling. Typical farmers today will have at least two or possibly three fuels in storage (gasoline, diesel and LPG). The arrangement would eliminate the need for service station type distribution in the area.

1. Data Loging. Each research vehicle would be equipped with a Omnidata data loger which would have a 16 channel input with a 64,000 character storage and would be capable of monotoring the performance of the vehicle for a 20 hour period which would no rmally encompass two weeks of anticipated activity. Although not all of the specific inputs have been defined those that would be monitoroed include: RPM of the crank shaft (tachometer), RPM of the output shaft from the transmission, ground speed of the vehicle, fuel consumption rate, coolant temperature, outdoor ambient, exhaust manifold temperature, intake manifold temperature, fuel temperature, real time and combustion air intake temperature (for carbonated units). These readings would be sampled an d loged every 10 - 20 seconds.

The data loger and the associated sensory equipment would be installed by the Automotive Technology Section of the Carroll branch of the Des Moines Area Community College (DEMAC). Every one or two weeks (depending on usage patterns) the data logers woul d be off loaded into a 1500 Zenith portable computer which is compatible to the data loger. This would be done at the Automotive and Agricultural Engineering Vocational Center at the Audubon Community High School in Audubon. The data from the Zenith un it would then be transfered to an IBM PC/AT at the Audubon Industrial Development Corporation for evaluation.

2. Fuel Analysis and Formulations. Preliminary arrangements have been made with a fuel alcohol plant, ADCII * at Hamburg, Iowa. This arrangement has been tentatively sanctioned by the BATF's regional office in Chicago. The hydrous ethanol fuel from t he ADCII would be sold to an ethonal fuels research company in the Audubon area which would have a permit from the BATF to do experimental research and evaluations of ethanol fuels. This would include analysis of denaturants that are inherent in the fue l prior to the cyclohexane or molecular sieve dehydration of the ethanol to the anhydrous form (which is the normal product sold by the Hamburg facility), detergents and other additives that would be incorporated in the fuel, which would then be evaluate d by the BATF to determine if these components would constitute a legal denaturant.

* or ADC-II

An analysis of performance of the U.S. fuel would be compared against the performances of the Brazilian fuel composition. To the extent possible an attempt would be made to emulate the conditions and analysis of the Brazilian produced hydrous ethanol fu el.

3. Maintenance Analysis. Periodically the units would be returned to the Automotive Technology Section of the Carroll Branch of DEMAC. Specialized personnel teaching courses in automotive technology will compare maintenance requirements with those tha t have been experienced by the Brazilian producers of the units.

Particular attention would be given to the cold weather operating conditions to determine if the lower temperatures being experienced in Iowa would have any unusual effect upon normal engine performance.

At the time the vehicles are acquired the Brazilian Manufacturer will recommend a package of spare parts that will be imported with the vehicles.

4. Emissions Testing. Equipment is being secured to enable emissions testing. This equipment was designed for conventional gasoline fueled vehicles. It is not known if this will be adequate to provide the necessary data for the EPA. It may be necessar y to ship emission samples to the University for a more detailed quantitative and qualitative analysis, particularly in regard to aldehydes. To our knowledge there is no testing equipment currently available that is designed specifically for ethanol fue led vehicles.

DESIGN MODIFICATIONS

It is anticipated that some modification for cold weather starting of these vehicles may be necessary. This is in an area in which the University of Iowa has gained considerable experience in its research work with Ford Tractor Operations, which include d a combination of block heaters, preheated intake air (which is passed over the exhaust manifold), fueled heaters, propane starting fuel plus a number of other design alternatives with which we are aware. In addition one of the units should possibly be factory equipped with a fuel injection system. It is anticipated, however, that the fuel injection may have to be a retrofit, and this eventuality has already inaugerated a search for appropriate hardware. We also have the advantage of using the Centr al Scientific Research Laboratory on alternative fuels in Ford-Dearborn for design-engineer counsel.

SELECTION OF SPECIFIC SITES FOR VEHICLE TESTING

It has been understood by all concerned that this test program is not being inaugerated for publicity purposes or to sell some sort of public relations image. The units will be tested in an environment that is strictly rural. Although it will be known i n the small community of Audubon that these tests are taking place, there is no intention to encourage public demonstration of these vehicles during the test period, other than what is unavoidable. The location of the units will be selected by a three m an committee that are all Audubon area locals who are either farmers, or have local business interests.

The units are to be used in the same pattern and to perform the same tasks as would be typical for a light weight pickup employed on the farm -- which would include hauling small loads, and farm to city to school travel. It is anticipated that the vehic les would be housed each night on the farmstead. The vehicle operators would carry their own insurance on the vehicle, although the licensing and ownership would be considered as part of the state vehicle fleet titled to the University of Iowa and would carry a state licensing, the latter to be sanctioned through the Vehicle Registration of the Motor Vehicles Division of the Iowa DOT.

TAXES.

There would be no state tax on the ethanol fuel used in the vehicles as this activity would be considered as "in the public service". As mentioned, the vehicles would be owned by the University of Iowa as test and research vehicles.

SUMMARY.

There is a large body of knowledge on the operation and economics of dedicated, ethanol fuel over the road vehicles that has never been scientifically evaluated. There are over a million of these vehicles on the road in Brazil.

This University has, for most of the decade, been involved in evaluating the technical and economic aspects of ethanol produced from corn and ethanol utilization. This University has also done much work in corn utilization in general.

The principle objectives of this project is to establish, using state-of-the-art production -- engineering design, where ethanol fueled vehicles are -- in terms of economic and technical viability. And do these vehicles represent an alternate transporta tion concept, that this country should consider as a partial solution to our over production of corn, as a means of providing some improvement in our balance of payments, and improve our national security by reducing our dependence on imported oil.

We respectfully request your approval of our undertaking.

Sincerely,

ID: nht87-3.38

TYPE: INTERPRETATION-NHTSA

DATE: 12/07/87

FROM: RICHARD H. SCHULTZ -- AMERICAN PULSE LIGHTS INC

TO: ROBERT J. KNAUFF

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 07/24/89 FROM STEPHEN P. WOOD -- NHTSA TO ROBERT KNAUFF; REDBOOK A33; FMVSS 108; LETTER DATED 06/08/89 FROM ROBERT J. KNAUFF -- APPLIED RESEARCH AND DESIGN INC TO KATHLEEN DEMETER -- DOT; LETTER DATED 08/16/88 FROM RICH ARD H. SCHULTZ -- AMERICAN PULSE LIGHTS INC TO ROBERT KNAUFF

TEXT: Dear Mr. Knauff:

It was good to hear from you today and I'm glad that you are proceeding in a proper manner regarding the single-pulse signal enhancement feature that you propose to market for use in certain stop signal lamps.

As we discussed, there should be no intensity problem with the use in W, W2 and W3 types because there is no maximum intensity written into the standards for those lamp types. The lamp design intensities also generally far exceed what the three "W" stan dards call for, so any masking of the reflector in the lamp by the photo tube should not prevent adequate performance.

The flash energy formula described in SAE J1318 APR86 (S2.11) may be used to determine compliance with the maximum intensity requirement of SAE "U" type supplementary stop lamps. In J1318, class 1 directional lamps (table8) require 50 candela-seconds of flash energy at H-V. The same functions type lamp and test location in SAE J595 AUG83 (table 1) requires 300 cd intensity. This is a ratio of 1:6. It therefore follows that the maximum from flash energy in an SAE "U" type with a 60 cd limit should be 10 candela-seconds.

When you can obtain a test report that indicates the candela-seconds in an SAE "U" lamp, I would like to see a demonstration of the tested arrangement for assurance that there is no "discomfort" glare at that level. This is primarily because we have a t otally new concept here and we want to be on the safe side. Same goes for use in school bus type "W2" lamps. The momentary light will be paler than the limit for red specified in SAE J578d color standard, but if it is not within the limit for white, it will be an acceptable color.

You said that there is no problem with setting higher or lower intensities if necessary, so you should be able to proceed with your formal request for authorization after the test and demonstration go as anticipated.

Sincerely,

ID: nht87-3.39

TYPE: INTERPRETATION-NHTSA

DATE: 12/08/87

FROM: STEVE ZLOTKIN -- CEO OVERLAND PARTS INC

TO: ERIKA Z. JONES -- NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 09/12/88 FROM ERIKA Z JONES TO STEVE ZLOTKIN; REDBOOK A32, STANDARD 205

TEXT: Dear Ms. Jones:

We are importers of automotive products including automotive glass.

We have need to import a windshield which fits the 1953 to 1967 Volkswagen transporter or "bus" which is a multipurpose vehicle.

Our supplier does not have laminated windshields for that model but does have non-laminated windshields.

Thus, the question is, (can we legally import and sell non-laminated windshields for that model since the United States windshield standards were not adopted until 1968)? Because it might concern you I will add that it would be impossible to install one of these windshields into a 1968 or later vehicle. There is a great physical difference in size on the later model.

If need be we would be willing to placard or sticker each windshield notifying the customer that it is not laminated, or that it is restricted to use on certain year buses if the entire span of 1953 to 1967 is not permissible.

I would appreciate your opinion.