ID: nht87-2.28

TYPE: INTERPRETATION-NHTSA

DATE: 06/29/87

FROM: SIDNEY A. GARRETT -- PRESIDENT BROWN CARGO VAN INC

TO: TAYLOR VINSON, LEGAL COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 09/28/87 FROM ERIKA Z. JONES -- NHTSA TO SIDNEY A. GARRETT, REDBOOK A31, STANDARD 102, STANDARD 108, TRUCK SIDE MARKETS

TEXT: Dear Mr. Vinson,

We are manufacturers of truck van bodies and would like to have an interpretation of the regulations regarding the placement of intermediate lamps and reflectors. We are currently installing lights on our upper rail and reflectors just above the lowe r rail as indicated on the attached drawings.

We are of the opinion that we are installing lights and reflectors on the front part of each side that are unnecessary under current federal regulations.

Would you please send us your interpretation of these regulations for our files. Additionally, could you indicate whether compliance with federal regulations constitutes compliance with the various states' regulations since our van bodies are sold ac ross the country.

Thank you for your attention to this matter.

Sincerely,

ENCLOSURE

(DRAWING OMITTED)

ID: nht93-2.11

DATE: March 9, 1993

FROM: D. E. Dawkins -- Director, Vehicle Compliance and Safety Affairs, Chrysler Corporation

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: Re: NHTSA Letter of February 18, 1993 Regarding the Chrysler Corporation Petition to Manufacture 10 Chesapeake Consortium Electric Vehicles

ATTACHMT: Attached to letter dated 3-24-93 from John Womack to Dale E. Dawkins (A40; Part 555)

TEXT: This letter responds to your referenced letter and the subsequent phone conservation with Mr. Len Blazic of my staff on March 1, 1993.

Chrysler Corporation desires to manufacture ten Chesapeake Consortium Electric Vehicles (CCEV'S) that would have no discernable safety differences to the electric TEVan vehicles, which have already been granted exemption from three MVSS's. All compliance aspects of this program remain unchanged from that of the TEVan program. The only difference between the two programs of electric vehicle development is the propulsion motors and transmissions, as were outlined in our December 16, 1992 letter.

We believe that this will satisfy your need for additional information.

ID: nht93-4.46

DATE: June 25, 1993

FROM: Thomas Luckemeyer -- SWF Auto-Electric GmbH

TO: Taylor Vinson -- Office of the Chief Counsel

TITLE: Turn Signal Lamp

ATTACHMT: Attached to letter dated 7-8-93 from John Womack to Thomas Luckemeyer (A41; Std. 108)

TEXT:

Thank you very much for your detailed answers, which you have sent us by fax on May 28. Nevertheless we have an other question to you with respect to the acceptability of a multiple rear turn signal lamp under FMVSS Standard No. 108.

You applicate the SAE J 588 Nov. 84 but the 1990 SAE Ground Vehicle Lighting Manual instructs us to applicate the SAE J 588 Sept. 70. Which SAE Standard is the right one?

Please send us an actual copy of the "Table III - Required Motor Vehicle Lighting equipment - Cont." from the FMVSS standard No. 108.

Please send your answer by fax.

Address see above.

Thank you in advance for your help.

ID: nht68-4.12

DATE: 09/10/68

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

TO: National Highway Users Conference

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 23, to Mr. George Nield, concerning the compliance of crane carriers and fire engines with Federal Motor Vehicle Safety Standards 103 and 104.

The crane carrier you have described is a "motor vehicle" subject to the provisions of the National Traffic and Motor Vehicle Safety Act of 1966. For purposes of the Federal Motor Vehicle Safety Standards the described crane carrier is classified as a "truck." Although currently Federal Standards 103 and 104 do not apply to trucks both standards, by amendment, issued April 24, 1968, (33 F.R. 6466-69), will be applicable to trucks manufactured on or after January 1, 1969.

Similarly, a fire truck is a "motor vehicle" and a "truck" and subject to all Federal Motor Vehicle Safety Standards applicable to this category of vehicle, including Standards 103 and 104. However, the open cabs found on many fire trucks may make full compliance with Standard 103 impossible. A public docket, Docket No. 24, has been established to receive comments pertaining to the possible classification of fire fighting equipment as a separate vehicle category which might be exempt from certain standards.

ID: 13523.drn

Mr. Jerome A. Hoover
Compliance Engineer
Monaco Coach Corporation, Indiana Division
P. O. Box 4313
Elkhart, IN 46514-0313

Dear Mr. Hoover:

This responds to your request for an interpretation whether a world manufacturer identifier (WMI) assigned to Roadmaster Rail, Inc. (Roadmaster) can continue to identify Roadmaster after Monaco Coach Corporation (Monaco) purchases Roadmaster. Under the facts described below, since Monaco is not assigned a WMI and intends to continue use of the Roadmaster name, Monaco may use Roadmaster's WMI.

Your letter states Roadmaster and Holiday Rambler are divisions of Monaco. Roadmaster manufactures incomplete vehicles, and Holiday Rambler and Monaco are final stage vehicle manufacturers. You wrote that "Monaco has full liability for the Roadmaster chassis, and for Monaco and Holiday Rambler motorhomes."

In a telephone conversation with Dorothy Nakama of my staff, you explained that Monaco does not manufacture any vehicles in one stage or any incomplete vehicles, and is not assigned a WMI. You stated that before Monaco acquired Roadmaster in 1993, Roadmaster was an independent company, not part of another company. You stated that Monaco does not intend to merge Roadmaster into Monaco but to keep Roadmaster as a separate division, and to advertise Roadmaster as a trade name. You also stated that Holiday Rambler was once an independent company and is assigned its own WMI because it manufacturers trailers and fifth wheels.

NHTSA's regulations at 49 CFR Part 565 Vehicle Identification Number Requirements states that the WMI shall "uniquely identify the manufacturer, make and type of the motor vehicle if its manufacturer produces 500 or more motor vehicles of its type annually." (49 CFR section 565.6(a)) In past interpretation letters, NHTSA has interpreted "uniquely identify" to mean that the same WMI cannot be used for two corporate entities if there is a possibility the two entities will be confused.

Your case is one of first impression. Unlike similar situations we have addressed, no WMI is assigned to the parent company (Monaco), but each division (Roadmaster and Holiday Rambler) has a separate WMI. You assure us that there are no plans for Monaco to be a one stage vehicle manufacturer or an incomplete vehicle manufacturer (which would require assigning a WMI).

Since Monaco itself is not assigned a WMI, and but each of its divisions, Roadmaster and Holiday Rambler has separate WMIs, we agree that Roadmaster and Holiday Rambler may continue to use the WMI assigned to each company. Under the facts described, there would be no confusion as to which corporate entity manufactured the applicable vehicle. Also, separate WMIs for the two divisions make it possible to distinguish between vehicles built by Roadmaster and Holiday Rambler.

I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,

John Womack

Acting Chief Counsel

ref:565

3/20/97

ID: 20146.drn

Dr. Barbara Goodman
Director, Pupil Transportation
Commonwealth of Virginia
Department of Education
P.O. Box 2120
Richmond, VA 23218-2120

Dear Dr. Goodman:

This responds to your request for an interpretation on the continuing validity of the National Highway Traffic Safety Administration's interpretation letter of August 11,1987, to Mr. Ernest Farmer, Director of Pupil Transportation of the Tennessee Department of Education on refurbishing school buses.

This letter confirms that the August 11, 1987, interpretation letter to Mr. Farmer is still valid. For your information, I am enclosing a copy of a May 2, 1988, interpretation letter to Robert R. Keatinge, Esq. The Keatinge letter clarifies the Farmer letter by explaining that in interpreting 49 CFR 571.7(e), the Farmer letter understood the bus bodies involved to be new. Therefore, the Farmer letter did not purport to address the question of combining an old bus body with new and/or used chassis components.

I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:VSA#571.3
d.7/16/99

ID: nht79-4.27

DATE: 10/15/79

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Bureau of Motor Vehicles

TITLE: FMVSR INTERPRETATION

TEXT: This is to memorialize the telephone conversation you had with Kathy DeMeter of my staff on Thursday, October 4, 1979, concerning the motor vehicle manufacturers' certificate of origin. You indicated to Ms. DeMeter that the new standard certificate of origin has an assignment form on the reverse side for the transfer from the first dealer to the consumer. This assignment contains odometer information, including identifiers of the vehicle, a reference to Federal law, a statement of the odometer reading, a statement that the reading is actual unless one of two other statements (mileage not actual or mileage over 99,999 miles) is checked, the names and addresses of the buyer and the seller, and the signature of the seller. Ms. DeMeter informed you that in order for the certificate to substitute for a separate Federal odometer disclosure statement, it must include the signature of the buyer. Ms. DeMeter also indicated that when the assignment form is being used to transfer the vehicle from the dealer to another, the odometer information is not required under Federal law.

ID: nht87-1.41

TYPE: INTERPRETATION-NHTSA

DATE: 02/26/87

FROM: THERESA ROONEY -- ALPINE ELECTRONICS OF AMERICA, INC.

TO: ED GLANCY -- LEGAL COUNSEL, FMVSS-101 NHTSA

TITLE: RE: FMVSS-101

ATTACHMT: ATTACHED TO LETTER DATED 3/07/89 FROM ERIKA Z. JONES -- NHTSA TO THERESA ROONEY, REDBOOK A33, STANDARD 101

TEXT: Dear Mr. Glancy:

I am writing to you on recommendation from Mr. Cavey of the National Highway Traffic Safety Association. He suggested that I might contact you to get written confirmation of our interpretation of the above ruling to be enacted 9/1/89.

It is my understanding that any car sound system which has been factory installed must be equipped with light intensities that have two values, a higher one for day, and lower one for night. These two light intensities do not have to be variable and any color may be used to illuminate the system.

If possible, I would like to receive written confirmation of this correct interpretation from your office for our records.

Any assistance that you may provide in this matter would be greatly appreciated.

Sincerely,

ID: 8512

Mr. Carl W. Ruegg
President
Carlo International, Inc.
P.O. Box 250
Selma, CA 93662

Dear Mr. Ruegg:

This responds to your letter of March 29, 1993, to Taylor Vinson of this Office.

In response to your request for "information and regulations regarding the importation of non-conforming vehicles for research, investigation, studies, demonstrations," I enclose a copy of 49 CFR Part 591, the regulation governing the importation of motor vehicles and equipment subject to the regulations of this agency, and a copy of a final rule published March 8, 1993, that amends the regulations. Sections 591.5(j), 591.6(g) (as amended), and 591.7 (as amended) apply to your inquiry.

If you have any questions regarding the interpretation of the regulation or amendments, you may contact Mr. Vinson (202-366-5263). Questions regarding the implementation of the regulations, such as the information deemed acceptable to acquire the agency's pre-entry letter of approval, should be addressed to the Office of Vehicle Safety Compliance. You may contact Clive Van Orden with questions of this nature (202-366-2830).

Sincerely,

John Womack Acting Chief Counsel

Enclosure ref:591 d:4/l3/93

ID: nht93-2.49

DATE: April 13, 1993

FROM: John Womack -- Acting Chief Counsel, U.S. Department of Transportation, NHTSA

TO: Carl W. Ruegg -- President, Carlo International, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 3-29-93 from Carl W. Ruegg to Taylor Vinson (OCC 8512)

TEXT: This responds to your letter of March 29, 1993, to Taylor Vinson of this Office.

In response to your request for "information and regulations regarding the importation of non-conforming vehicles for research, investigation, studies, demonstrations," I enclose a copy of 49 CFR Part 591, the regulation governing the importation of motor vehicles and equipment subject to the regulations of this agency, and a copy of a final rule published March 8, 1993, that amends the regulations. Sections 591.5(j), 591.6(g) (as amended), and 591.7 (as amended) apply to your inquiry.

If you have any questions regarding the interpretation of the regulation or amendments, you may contact Mr. Vinson (202-366-5263). Questions regarding the implementation of the regulations, such as the information deemed acceptable to acquire the agency's pre-entry letter of approval, should be addressed to the Office of Vehicle Safety Compliance. You may contact Clive Van Orden with questions of this nature (202-366-2830).