ID: nht78-4.16

DATE: 02/24/78

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Emil M. Mrak

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 30, 1978, to Ms. Joan Claybrook, Administrator of the National Highway Traffic Safety Administration (NHTSA), concerning the seat belts in your Cougar automobile.

Your original letter of December 12, 1977, to Secretary Brock Adams, complaining about the seat belts in your automobile has been answered. A copy of our reply is enclosed to this letter and is still relevant to your problem.

As long as the lap-shoulder belt intersection is not less than 6 inches from the vertical centerline of the driver, any other location that is confortable and easy to use is allowable. We suggest that you again contact your dealer to determine if the belt arrangement can be modified to be better suited to your condition and yet have the belt configuration remain within the NHTSA requirements.

SINCERELY,

January 30, 1978

Honorable Joan Claybrook Department of Transportation

Dear Miss Claybrook:

I have been in correspondence with the Ford Motor Company concerning the inadequacies of the seat belts in their new cars, and especially the Cougar.

I am enclosing copies of correspondence that I have had with the Ford Motor Company and the Department of Transportation, and this latter has not been answered.

The present seat belt arrangement is almost impossible for a person of my age to use. If the attachment on the right side of the driver were six inches longer it would be easy to use. As it is, when I drive around town I am not using a seat belt, although I would prefer to use one. When I take longer trips, I use it and, if my wife is along, I have her assistance in attaching it. If she is not along, I struggle and struggle until finally I get it attached.

It is of interest to me that the Ford Motor Company blames the Department of Transportation for this inadequacy. I just can't believe it. If it is the fault of the Department of Transportation I hope the Department will correct it.

If the Department of Transportation can't help in this matter, then I plan to take it up with some member of Congress.

As you well know, we got rid of the interlock system. I think this can be corrected too.

VERY TRULY YOURS, Emil M. Mrak

602 CORDOVA PLACE DAVIS, CA 95616

December 12, 1977

The Honorable Brockman Adam The Secretary of Transportation

Dear Mr. Adams:

Sometime ago I wrote the Ford Company complaining about the inaccessibility of the short portion of the seat belt to a person who is up in years. I pointed out that because of the extreme difficulty of hitching these up, more and more people are failing to use seat belts. Furthermore, the twisting and squirning required could very well result in backbone injuries to elderly people.

I was astounded to receive a letter from the Ford Company indicating that the Federal Standards required such a belt. This is hard for me to believe. In any event, I would appreciate knowing if what they told me is the truth, and if it is, then, the truth, I would strongly recommend that this requirement be revised. If it is not a requirement, then I think the Ford Company should be told to take the blame off the Department of Transportation.

If Congressional help is needed to make such a change, I would be glad to pursue it.

I am enclosing copies of my letter to Mr. Wilson of the Ford Company and also his reply, which as (Illegible Words) astonished me.

VERY TRULY YOURS, Emil M. Mrak

ID: nht78-4.17

DATE: 01/09/78

FROM: AUTHOR UNAVAILABLE; Joan Claybrook; NHTSA

TO: Department of Transportation - Wisconsin

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your September 20, 1977, letter asserting that the Wisconsin requirement for minimum seat spacing does not conflict with the Federal requirement for maximum seat spacing found in Standard No. 222, School Bus Passenger Seating and Crash Protection.

Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) (15 U.S.C. 1381 et seq.) specifies that no State shall have in effect a safety standard concerning an aspect of performance regulated by a Federal safety standard, unless the State standard is identical. The Act provides a limited exception to the above where a State or local municipality has a requirement which applies only to vehicles purchased for their own use and which imposes a higher standard of performance. Both Standard No. 222, which regulates maximum seat spacing, and the Wisconsin standard, which regulates minimum seat spacing, regulate the same aspect of performance. This position is supported by our statements in Notice 5 of Standard No. 222 (41 FR 4016) which expressed the opinion that seat spacing is the regulated aspect of performance (copy enclosed). Since your State standard is not identical to the Federal standard, it is the opinion of the NHTSA that it is preempted.

You should note that although you are not permitted to impose this State standard on all vehicles used in your State, the Federal government does not preclude you from purchasing any buses for your own use from among the several designs now in production. You could, therefore, purchase only those vehicles that afford you the minimum knee space you desire. You should note further that purchase for your own use has been interpreted to mean purchased by a contractor under contract to provide transportation for school children.

SINCERELY,

State of Wisconsin / DEPARTMENT OF TRANSPORTATION

DIVISION OF MOTOR VEHICLES

September 20, 1977

Joan Claybrook, Administrator NHTSA Office of the Administrator

Dear Ms. Claybrook:

Re: Letter to you from Mr. Robert Kurre, Wayne Corporation Date September 2, 1977

The State of Wisconsin stoutly defends it's position that there is no point of conflict between the FMVSS 222 relating to seat spacing and the Wisconsin Administrative Code, MVD 17.

FMVSS dictates a maximum space permitted (for compartmentalization) for persons riding in school buses. The Wisconsin rule states a minimum distance that is permissible.

The engineering staff at Wayne Corporation was aware of these two non-conflicting standards as of February 23, 1977. It appears to us that this should have been adequate lead time to design and test seats that can meet both the federal and state standard.

To emphasize this point, we have been advised by one manufacturer of school bus bodies that they are meeting both federal and Wisconsin standards on buses manufactured after April 1, 1977. It is the State of Wisconsin contention that it is merely a matter of proper design by the manufacturer to meet both requirements.

The Wisconsin standard was developed because of the concern for adequate knee room in the seats. The federal standard has no minimum knee room, therefore, if a manufacturer wished to have, for instance only 20 inches of knee room, he could so produce a bus and not be in conflict with the federal standard. This is what we have prevented by the implementation of our minimum spacing measurement. We have observed buses built to less than the 24 inch minimum spacing and they are unacceptable for the cross section of pupil transportation in Wisconsin.

To carry this a bit further, the State of Wisconsin subscribes to the proposal that the federal government interpret the 20 inch measurement from the seating reference point be made at the closest point between the seat back rather than have this at the widest point.

We believe Mr. Kurre is in error by stating that the State of Wisconsin has a standard in conflict with a federal standard. We further believe that our 24 inch measurement is the extreme minimum that is necessary for transportation of any school children in Wisconsin

If I can supply you with additional information in this matter, please advise.

JAMES O. PETERSON Administrator

cc: Col. LEW V. VERSNIK; CARL H. ZUTZ

ID: nht78-4.18

DATE: 03/20/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Nebraska Dept. of Motor Vehicles

COPYEE: R. TILTON; ARMSTRONG; HITCHCOCK

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your January 16, 1978, letter asking several questions about the applicability of the school bus regulations to school buses manufactured after April 1, 1977, transporting 10 or more students to or from school or related events.

You first ask whether these buses must be painted yellow and have school bus lighting and markings. The answer to your question is yes. Any vehicle that transports 10 or more students to or from school or related events is a school bus and must have the painting, marking, and lighting of a school bus.

Your second question is whether smaller school buses (vans) are permitted to have van-type seats or must comply with the requirements of Standard No. 222, School Bus Passenger Seating and Crash Protection. A vehicle that transports 10 or more students must comply with all of the Federal school bus regulations, including the seating standard.

ID: nht78-4.19

DATE: 01/25/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Mercedes-Benz of North America Inc.

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of December 19, 1977, you have requested "a testing exemption" for one diesel car to be operated by your technical service department for 1 year, "to determine the marketing potential of a vehicle of this kind."

No exemption is necessary. Pursuant to 19 CFR 12.80 (b)(2)(vii) simply check Box 7 of the HS-7 Form that must be executed upon the vehicle's entry, and attach to the form a sheet explaining the purpose for which the vehicle is imported, the length of time it will be used on the public roads, and its intended disposal after that time.

Sincerely,

ATTACH.

MERCEDES - BENZ OF NORTH AMERICA, INC.

December 19, 1977

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

Subject: Request for Testing Exemption for One 307 Van

Dear Ms. Claybrook:

We would like to request a testing exemption for:

One Mercedes-Benz 307 Van, 3.5 tons (7,716 lbs.), Wheelbase 3,350 mm (131.9 in.), equipped with OM 616 - diesel engine (4 cyl., 146 cu. in.).

This vehicle will be operated by our Technical Service Department in Montvale, N. J. We propose to determine the marketing potential of a vehicle of this kind.

We are planning to have the vehicle in service for 1 year starting in February 1978. After this time, the vehicle will be shipped back to Germany.

Please feel free to contact us if any further information is needed.

Sincerely yours, K. H. Faber

ID: nht78-4.2

DATE: 01/13/78

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: State Farm Insurance Companies

TITLE: FMVSR INTERPRETATION

TEXT: This is to confirm your telephone conversation of December 1, 1977, with Kathy DeMeter of my staff. The question you raised was whether odometer disclosure statements have to be executed under section 580.4 and retained under section 580.7 of title 49, Code of Federal Regulations when the vehicle involved is a salvage vehicle.

If the vehicle is repairable and will subsequently be used as a motor vehicle, disclosure would have to be made. Likewise, the disclosure statements would have to be maintained if section 580.7 is adopted as a final rule. However, if the vehicle is so badly damaged that it cannot be returned to the road, it will have ceased to be a motor vehicle for purposes of the regulations. Disclosure would therefore not be required.

ID: nht78-4.20

DATE: 05/01/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin, Jr.; NHTSA

TO: National Tire Dealers & Retreaders Association, Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 23, 1978, letter asking whether the National Highway Traffic Safety Administration's (NHTSA) interpretation concerning the registration of passenger car tires can be applied to the registration of truck tires. In that interpretation, the NHTSA stated that it was permissible for a tire dealer to allow the tire purchaser to fill out the tire registration form and hand it back to the dealer.

The NHTSA's interpretation is applicable to both truck and passenger car tires. A truck tire dealer may permit a purchaser to fill out the required information rather than completing the registration form himself. However, this all must occur at the point of sale of the tire. The registration forms for both passenger car tires and truck tires are not permitted to be taken home or shipped with the tires to be completed by the purchaser and subsequently returned or mailed to the dealer. This would impair the benefit of mandatory tire registration and make it a voluntary program. This is not the intent of the regulation, and the NHTSA would not consider such a registration program to be in compliance with the tire registration regulation.

SINCERELY,

NATIONAL TIRE DEALERS & RETREADERS ASSOCIATION, INC.

February 23, 1978

Roger Tilton National Highway Traffic Safety Administration

Dear Mr. Tilton:

As you know, NHTSA has issued a interpretation of the regulations regarding tire identification and record keeping, which permits the tire dealer to hand to the consumer of passenger tires a form which the consumer may fill out at the dealers place of business.

Since a similar type of problem now exists in the sale of truck tires the question has been raised on registration there also.

It it permissible for a tire dealer, selling to a trucker, to give the trucker a form to fill out and return to the individual dealer? In some cases truck tires are shipped directly from the manufacturer to the trucker and the dealer may not have even a direct contact on every shipment.

Letting the cards accompany the tires or providing the registration cards to the trucker might be helpful. We would appreciate some guidance on this so we may advise our membership.

Philip P. Friedlander, Jr. Executive Vice President

ID: nht78-4.21

DATE: 08/08/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin, Jr.; NHTSA

TO: Euro-Tire, Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your June 1, 1978, letter asking whether it is acceptable for you as a tire distributor to use your own tire registration form as long as it complies with the requirements of Part 574, Tire Identification and Record-keeping.

Part 574.7 of the Code of Federal Regulations (CFR) provides that a dealer of tires may supply his own form on which to record information specified in paragraphs (a)(1), (a)(2) and (a)(3), as long as the form contains the required information, conforms in size and is similar in format to the "Universal Format" form set forth in Figure 3 of that part. The form designed by Euro-Tire appears to meet the requirements of Part 574. Accordingly, it is acceptable for use in fulfilling the tire recordkeeping requirements.

SINCERELY,

June 1, 1978

Office of Chief Counsel U.S. Dept. of Transportation N.H.T.S.A.

Gentlemen:

Euro-Tire, Inc. is a retailer of several brands of passenger car tires.

Because of the nature of our operation, the registration of D.O.T. tire identification numbers as required by law has become very time consuming and costly to us.

Since our operation is fully automated, it would be advantageous to us to record the required information for the various brands of tires we sell on one universal form rather than on the several different forms provided by our supplier-manufacturers or their agents.

Attached is a photocopy of the form we designed for this purpose. The sample typewritten information, namely, customer name and address, date of sale and brand name, will be computer printed.

We believe that our form meets all the informational and dimensional requirements of NHTSA's "universal format" and that it complies substantially with the layout of the "universal format".

We would appreciate your reviewing our form and advising us promptly as to whether or not is is an acceptable substitute for the several different forms provided by our suppliers for registration purposes.

EURO-TIRE, INC.

Martin P. Ronsen President

IMPORTANT: Federal law requires registration of all tires purchased for highway use.

SOLD TO

JOHN Q CUSTOMER 1234 MAIN ST APT 34 ANY CITY NJ 07000

SOLD BY

euro-tire

EURO-TIRE, Inc. 1275 Bloomfield Ave. Fairfield, NJ 07006

DATE OF SALE 6/01/78

TIRE BRAND SUPERSLICK QTY D.O.T.TIRE IDENTIFICATION CODE 3 A 7 G X K L M N 3 5 7 1 A 7 G X K L M N 3 9 7

June 29, 1978

Office of Chief Counsel U.S. Dept. of Transportation N.H.T.S.A.

Att.: Nancy Eager, Esquire

Gentlemen:

We are enclosing a copy of our letter dated June 1, 1978 together with a copy of the proposed format we designed for the registration of D.O.T. tire identification numbers.

Your prompt attention to this matter would be greatly appreciated.

EURO-TIRE, INC.

Martin P. Ronsen

ID: nht78-4.22

DATE: 08/11/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Cars & Concepts, Inc.

TITLE: FMVSR INTERPRETATION

TEXT:

August 11, 1978

Mr. Glenn Abbott Cars & Concepts, Inc. 12500 E. Grand River Brighton, Michigan 48116

Dear Mr. Abbott:

This is in response to your letter dated June 27, 1978, asking whether fog lamps mounted to the surface of a vehicle bumper are removed prior to testing for compliance with Part 581, Bumper Standard.

Vehicles subject to the requirements of Part 581 must comply with the protective criteria of section 581.5(c) (49 CFR 581.5(c)) when tested under the conditions stated in section 581.6 (49 CFR 581.6). The test conditions make no provision for removal of fog lamps prior to testing. As was the case under Federal Motor Vehicle Safety Standard 215, Exterior Protection, the Part 581 test procedures provide for removal only of trailer hitches before testing. With the added exception of license plate brackets, excluded from the requirements of Part 581 by interpretation (42 FR 24056; May 12, 1977), other equipment (including fog lamps) attached to the bumper system prior to sale of the vehicle to its first purchaser must meet the damage limitations of the standard.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

June 27, 1978

Mr. Joseph Levin Office of the Chief Counsel N.H.T.S.A. Department of Transportation 400 7th Street S.W.

Washington, D.C. 20590

Dear Mr. Levin:

Cars & Concepts, Inc. is preparing a prototype Dodge Omni "Rally" for a 1980 model year production program. It is proposed that Chrysler Corporation ship completed vehicles to one of our facilities where we would attach certain pieces of equipment comprising the "Rally" package. The vehicles would then be shipped back to Chrysler for distribution through their normal channels. Included in the "Rally" package is a pair of Cibie C-95 white fog lamps. These would be made inoperable for highway use by means of an easily removable fuse mounted to the instrument panel. The lamps would be mounted to the top surface of the bumper (to comply with certain state regulations) and closely enough to the vehicle centerline to avoid the normal beam path of the headlights. To avoid contact with the grille when the bumper is fully compressed, it will be necessary to mount the lamps close to the bumper face placing them in potential danger of being damaged in a 5 mph pendulum test. It is our understanding that under the provisions of FMVSS #215 such items were routinely removed before testing. We are concerned that the status of accessory lighting would change under FMVSS part 581 and would like a clarification of this.

Thank you for your assistance in this matter.

Sincerely,

Glenn Abbott Design

GA/dma

cc: D. Chrysler E. Hopp D. Draper M. Pare

ID: nht78-4.23

DATE: 12/04/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin, Jr.; NHSTA

TO: U.S. Army Tank-Automotive Material Readiness Command

TITLE: FMVSS INTERPRETATION

TEXT:

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

DEC 4 1978

NOA-30

Mr. Robert J. Shirock Safety Director U.S. Army Tank-Automotive Material Readiness Command Department of the Army Warren, Michigan 48090

Dear Mr. Shirock:

This is in reply to your letter of November 13, 1978, to the Administrator questioning whether certain trucks procured by your Command comply with paragraph S4.5.4 of Federal Motor Vehicle Safety Standard No. 108.

That paragraph states "The stop lamps on each vehicle shall be activated upon application of the service brakes." You wrote that "when the hazard warning lights are activated the stop lamp cannot be activated upon application of the service brakes." The system you describe would be in compliance with Standard No. 108, if the stop lamps and signal lamps are optically combined, for the following reasons. Paragraph S4.4.1 allows combination of a stop lamp with a turn signal lamp (which provides the hazard warning signal). Paragraph 4.2 of SAE Standard J586c Stop Lamps, August 1970 (incorporated by reference in Standard No. 108 as the operative standard for stop lamps) requires that "When a stop signal is optically combined with the turn signal, the circuit shall be such that the stop signal cannot be turned on in the turn signal which is flashing."

This, of course, means that in a combination lamp the stop signal cannot be given while the hazard warning signal is being operated. If the Army deems it desirable it could require a different circuitry in combination lamps by which the stop lamps and hazard warning signal lamps could operate simultaneously, as military vehicles need not conform to Federal safety standards (49 CFR 571.7(c)).

Because several jurisdictions require slow-moving vehicles to use the hazard lamps while in motion, I am asking our Office of Rulemaking to review this prohibition. Thank you for bringing this matter to our attention.

Sincerely,

Joseph J. Levin, Jr.

Chief Counsel

DEPARTMENT OF THE ARMY US ARMY TANK-AUTOMOTIVE MATERIEL READINESS COMMAND WARREN, MICHIGAN 48090

DRSTA-CZ 13 November 1978

Administrator National Highway Traffic Safety Admin 400 7th Street, S.W. Washington, D.C. 20590

Dear Ms. Claybrook

Reference is made to FMVSS 108, paragraph S4.5.4.

Referenced paragraph states "The stop lamps on each vehicle shall be activated upon application of the service brakes."

Inspection of the lighting system in some commercial trucks recently procured by this Command disclosed that when the hazard warning lights are activated the stop lamp cannot be activated upon application of the service brakes.

While it is recognized that the primary purpose of hazard warning lights is to warn approaching traffic of a disabled vehicle, several states require the use of hazard warning signal for slow moving vehicles, i.e, NY Thruway, and Pennsylvania Turnpike. Application of the service brakes under this condition would not activate the stop lamps to warn following traffic.

Request this office be provided the DOT position as to whether or not the system described above meets the requirements of FMVSS 108, S4.5.4.

Sincerely yours,

ROBERT J. SHIROCK Safety Director

ID: nht78-4.24

DATE: 12/12/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: James P. Bally, Esq.

TITLE: FMVSS INTERPRETATION

TEXT:

U. S. DEPARTMENT OF TRANSPORATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION WASHINGTON, D.C. 20590

DEC 12 1978 NOA-30

James P. Bally, Esq. Messrs. Brownfield, Kosydar, Bowen, Bally & Sturtz 140 East Town Street. Columbus, Ohio 43215

Dear Mr. Bally:

We understand that you are interested in an interpretation of the relationship of a rear lighting system, developed by your client Mr. Leno Bevilacqua, to Federal motor vehicle lighting requirements. As you described this device in your letter of September 29, 1978, to the Nevada Department of Highways:

"The device will project a green light for the vehicle which would be in a constant or accelerated speed, a yellow light for the vehicle in a decelerated moving state and a red light for the vehicle which would be stopping."

Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, (49 CFR 571.108) neither requires nor expressly prohibits a lighting device of this nature as original equipment on motor vehicles. One section of the standard, however, S4.1.3, prohibits the installation of all original lighting equipment not mandated by the standard "that impairs the effectiveness of lighting equipment required by this standard." While we make no judgment with respect to Mr. Bevilacqua's 18-inch long 1 1/2 inch high rectangular device, I think it important to note that the agency's research into rear green signal lights indicate that there may be disadvantages rather than advantages to such a lighting system. One major disadvantage is the problem of confusing the unfamiliar colored rear lamps in urban environments having multicolored lights.

Standard No. 108 does not cover this device as an aftermarket item, and it would therefore be subject to regulation by the individual States.

Sincerely,

Joseph J. Levin, Jr.

Chief Counsel

U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION REGION IX TWO EMBARCADERO CENTER - SUITE 610 SAN FRANCISCO, CALIFORNIA 94111

October 24, 1978

Mr. James P. Bally Brownfield, Kosydar, Bowen, Bally & Sturtz Attorneys at Law 140 East Town Street Columbus, Ohio 43215

Dear Mr. Bally:

Your letter of September 29, 1978 concerning an automobile safety signal system with reference to Saflect Signal Corporation and Mr. Leno Bevilacqua, was forwarded to this office. You requested an interpretation concerning conformance to Federal requirements.

We have forwarded the correspondence to our Washington, D.C. headquarters for reply.

Sincerely,

Joseph F. Zemaitis Motor Vehicle Programs Specialist

cc: Associate Administrator for Rulemaking NHTSA, Washington, D.C.

state agencies, therefore, our expression or interpretation is only an unofficial expression of our view in an attempt to be of some assistance to you.

Very truly yours,

William H. Raymond Deputy Attorney General Assistant Chief Counsel Department of Highways

WMR/l

cc: Joe Souza, Highway Engineer Darwin Garvin, FHWA, 1 with enclosure Brian Nelson, Esq., Deputy Attorney General, DMV, with enclosure

STATE OF NEVADA OFFICE OF THE ATTORNEY GENERAL 12635 SOUTH STEWART STREET CARSON CITY 89712

ROBERT LIST MELVIN L. BEAUCHAMP ATTORNEY GENERAL October 10, 1978 DEPUTY ATTORNEY GENERAL CHIEF COUNSEL DEPARTMENT OF HIGHWAYS

Mr. James P. Bally Brownfield, Kosydar, Bowen, Bally & Sturtz Attorneys at Law 140 East Town Street Columbus, OH 43215

Dear Mr. Bally:

Your letter of September 29, 1978, to our Highway Engineer was referred to this office for reply. A copy of your letter is attached hereto.

We are also attaching a copy of Nevada's Motor Vehicle laws which relate to "lamps and other lighting equipment." While this Department is not directly involved with motor vehicles and vehicle equipment, it would seem the proposed safety signal system would be subject to regulation, specifically under the provisions of NRS 484.563.

We are sending a copy of your letter to the District Office of the Federal Highway Administration for possible comment. I have discussed this matter with Mr. Darwin Garvin who will, if he can be of assistance, reply to you directly or forward your request to the appropriate office.

In addition, we are sending a copy of your letter to Brian Nelson, Esq., Deputy Attorney General for the Department of Motor Vehicles, whose agency is responsible for enforcing the motor vehicle laws which contain the attached statutes. Since this is their area of expertise, they should be able to give you their interpretation of whether or not your proposed system would meet the legal requirements of our state.

If this office can be of further assistance, please feel free to request the same.

It is the policy of the Nevada Attorney General's Office to give statutory opinions only to state officials or