ID: nht79-2.12

DATE: 12/14/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Mack Trucks

TITLE: FMVSR INTERPRETATION

TEXT:

DEC 14 1975

Mr. Thomas F. Brown Mack Trucks Engineering Division P.O. Box 1761 Allentown, Pennsylvania 18105

Dear Mr. Brown:

This responds to your October 17, 1979, letter asking about the proper certification label for an intermediate manufacturer that alters the tires and rims on a chassis thereby affecting the gross axle and vehicle weight ratings. In your letter, you suggest an abbreviated certification label that would list the manufacturer's name and date of manufacture, and would make the statement that the vehicle will conform to certain standards if the incomplete vehicle document is followed. The agency agrees that this is a correct certification.

Intermediate manufacturers are required to attach labels to vehicles that they modify to indicate that some manufacturing operation has occurred on a vehicle between the manufacture of its chassis and its final manufacture. The intermediate manufacturer is permitted to select, from among a number of certification statements, the statement or statements that accurately represent the nature of the work undertaken by that manufacturer. Therefore, it is not necessary for an intermediate manufacturer to use all of the certification statements on its labels.

In the situation that you describe, the intermediate manufacturer will make a statement on its label identical to one of the statements made by the chassis manufacturer. Although this appears to be redundant, it is necessary to have the intermediate manufacturer's label on the vehicle making the required certification statement so that a final-stage manufacturer can continue to rely upon the certification labels and upon the statements made in the incomplete vehicle document.

Sincerely,

Frank Berndt Chief Counsel

October 17, 1979

Administrator, National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Madam: Subject: Request for Interpretation 49 CFR Part 567, Certification Intermediate Manufacturer's Label Section 567.5(b)

Mack Trucks, Inc., a manufacturer of heavy duty diesel trucks, requests interpretation of 49 CFR 567.5(b) concerning the "Intermediate Manufacturer's Label".

In the heavy duty truck industry, the practice of changing the tires and/or rims from those originally furnished on the incomplete vehicle, before delivery to a final-stage manufacturer, is not uncommon.

If a dealer (distributor) changes the tires and rims on a Mack chassis-cab, and the change alters the GAWR's and GVWR of the vehicle, then the dealer becomes an intermediate manufacturer since the validity of the incomplete vehicle document is affected (ref: 49 CFR 568.5). Therefore, the dealer is required to affix an intermediate manufacturer's label to the vehicle.

The requirements pertaining to the content of this label are specified in 49 CFR 567.5(b). As we interpret this section, only one of the four (4) statements (567.5(b)(2)) specified in 567.5 (b)(1) through (b)(3) possibly applies to a tire/GAWR/GVWR change since the conformance status of the safety standards has not changed. Therefore, the intermediate manufacturer's label could consist of only the following:

1. "This vehicle will conform to Standard Nos. ------------ if it is completed in accordance with the instructions contained in the amended incomplete vehicle document furnished pursuant to 49 CFR Part 568."

2. "INTERMEDIATE MANUFACTURE BY" followed by the dealer's name.

3. The month and year of intermediate manufacture.

In the case of a tire/rim/GAWR/GVWR change, statement 1 above, when completed, is simply a restatement of a sentence on the "Chassis-Cab Label" and seems redundant since the only difference between the two statements will be the word "amended".

Mack Trucks, Inc. would appreciate the Administration's comments on what is required of a dealer (distributor) who changes the tires/rims/GAWR/GVWR of an incomplete vehicle.

Very truly yours,

MACK TRUCKS, INC.

Thomas F. Brown Executive Engineer- Vehicle Regulations and Standards

vy

ID: nht78-2.1

DATE: 12/06/78

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

TO: American Honda Motor Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Brian Gill American Honda Motor Co., Inc. P.O. Box 50 Gardena, California 90247

Dear Mr. Gill:

This is in response to your letters of October 9, 1978, and October 20, 1978, concerning Federal Motor Vehicle Safety Standard No. 115, Vehicle identification number.

Since the agency was considering petitions for reconsideration when your letter was received, we concluded that it would be more helpful to respond to your letter after the revised standard was issued. A copy of the amendments to the standard and a copy of a notice of proposed rulemaking to further amend the standard are enclosed.

The type face shown in the attachment to your letter of October 9, 1978, meets the requirements of S4.3.1. Since the standard does not specify a location for the placement of the VIN on motorcycles, it may be stamped on the certification label. However, Honda should also consider stamping the VIN on the cycle frame as well, to aid in recovery if the motorcycle is stolen.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

Enclosures

October 9, 1978

Office of Chief Council NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 - 7th Street, S.W. Washington, DC 20591

Dear Sir:

Attached are sheets showing the format of the type face which Honda Motor Co., Ltd. intends to use for the vehicle identification number required by FMVSS 115.

Please inform me as soon as possible whether this type face meets the requirement of S4.3.1 of Standard number 115.

Yours truly,

AMERICAN HONDA MOTOR CO., INC.

Brian Gill Manager Certification Department

BG:lw

Enclosure

October 20, 1978

Office of Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 Seventh St. S.W. Washington, D.C. 20590

Dear Sir:

This is to request your official interpretation as to the suitability of a method for compliance with the requirement of section S4.3 of FMVSS 115, Vehicle Identification Number (V.I.N.). That section gives the general requirements for the part of the vehicle upon which the V.I.N. must appear.

Section S4.4 of the standard gives specific requirements for the location of the V.I.N. for passenger cars and trucks of 10,000 pounds or less GVNR but there is no such specification for other vehicles, such as motorcycles.

We respectfully request your confirmation that the requirements of S4.3 for motorcycles will be met if the V.I.N. is stamped on the label required by S 567.4 (e) of Part 567 - Certification.

Your earliest response will be appreciated. Please call me if you have any questions.

Yours truly,

AMERICAN HONDA MOTOR CO., INC.

Brian Gill Manager Certification Department

BG:rk

ID: 16362.ztv

Mr. Nick Tysoe
Development Engineer
Britax Vega Ltd.
Kingswood Road
Hampton Lovett Ind. Est.
Droitwich
Worcestershire
WR9 0QH
England

FAX 9-011-44-1905-796046

Dear Mr. Tysoe:

This is in reply to your fax of October 30, 1997, to Richard Van Iderstine of this agency. As the Office of Chief Counsel provides the written interpretations of the agency's regulations, please send future requests for interpretations directly to us.

You discuss the design of the rear of a vehicle which has one taillamp installed on the fender and another taillamp adjacent to it on the rear decklid. A distance of four inches separates the two lamps. Each of the lamps conforms to SAE J585 as a single lamp. You regard the fender-mounted lamp as the lamp required by Federal Motor Vehicle Safety Standard No. 108, and the lamp mounted on the decklid as an additional lamp that does not impair the effectiveness of the required taillamp. But if the two lamps are regarded as a two-compartment lamp, "their combined photometric performance will exceed by a small amount the 20cd maximum for such lamps."

You ask whether your interpretation is valid, or whether such an installation would be regarded as a multi-compartment lamp.

We are pleased to confirm your interpretation. A multiple compartment lamp is a lamp that shares a common housing and lens. Your design encompasses lamps with separate housings and lenses, and is not a multiple compartment lamp.

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.12/3/97

ID: nht95-2.53

TYPE: INTERPRETATION-NHTSA

DATE: April 25, 1995

FROM: Donnell W. Morrison

TO: Philip R. Recht -- Chief Counsel, NHTSA

TITLE: RE. -49CFR571.108-S4, Table 1; 49CFR571.108-S4, Table 11

ATTACHMT: ATTACHED TO 5/19/95 LETTER FROM JOHN WOMACK TO DONNELL W. MORRISON (A43; STD. 108)

TEXT: Dear Mr. Recht:

This responds to your April 10, 1995 reply to my February 14 and March 14, 1995 letters regarding the cited sections of the CFR.

If I understand your response the above cited sections of the CFR have not been amended since I left the DOT in March 1980. I therefore must conclude that the rear identification lamps required by 49CFR571.108 must be mounted as close to the top of the vehicle as is practicable.

My inquiry of March 14, 1995 mentioned the fact that I have seen many semitrailers on the highway with all the rear lights at bed level. By all lights I mean clearance, identification, stop, tail and turn signal lamps.

If the FMVSS108 has not been amended to allow all the rear lighting devices to be mounted at bed level has the NHTSA issued an interpretation to allow such mounting. If such an interpretation has been issued would it be possible for you to furnish me a copy.

I need to know where the rear lights have to be located to be able to finish my project and would appreciate a prompt response.

ID: nht88-2.51

TYPE: INTERPRETATION-NHTSA

DATE: 06/17/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: ROBERT CUZZI -- BREDA TRANSPORTATION, INC.

TITLE: NONE

ATTACHMT: MEMO DATED 12-9-87, FROM ROBERT CUZZI, TO ERIKA Z. JONES, RE: 020-1287

TEXT: This responds to your letter asking whether buses with a gross vehicle weight rating (GVWR) greater than 10,000 pounds are excluded from coverage under Federal Motor Vehicle Safety Standard No. 301, Fuel System Integrity. I regret the delay in respondin g to your letter.

The answer to your question is yes. Safety Standard No. 301 applies to new passenger cars, multipurpose passenger vehicles, trucks, and buses having a GVWR of 10,000 pounds or less and to all new school buses. The buses you manufacture for sale as muni cipal transit buses are excluded from Standard No. 301 because their GVWR is greater than the 10,000 pound limit established for the standard.

You asked also whether there are any other Federal standards that might apply to the fuel tanks on your transit buses. I have forwarded a copy of your letter to the Federal Highway Administration (FHWA) and the Urban Mass Transit Administration (UMTA) f or their direct reply as to the applicability of any FHWA or UMTA regulations to your transit vehicles. You might also contact the Environmental Protection Agency (EPA) to see whether that agency has any requirements affecting the fuel tanks on your bus es. The general telephone number for the EPA is (202) 382-2090.

ID: 77-2.27

TYPE: INTERPRETATION-NHTSA

DATE: 05/03/77

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Messrs. Allen & Korkowski & Associates

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of March 3, 1977, to Mr. Oates of this office asking whether your client, a manufacturer of motorcycle accessories, is subject to requirements imposed by 49 CFR Parts 573, 576, and 577 and 15 U.S.C. 1402.

For your reference I am enclosing a copy of a new Part 577 which becomes effective June 28, 1977, that implements Part B of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1411 et seq.) effective December 27, 1974. These new sections have superseded Section 1402, to which you referred. Since you apparently are unaware of these changes I am also enclosing a copy of the amended Act.

Because your client manufactures motor vehicle equipment other than original equipment (i.e. accessories) its products appear to be "replacement equipment" as defined by 15 U.S.C. 1419(2)(B). Since Parts 573 and 576 apply only to motor vehicle manufacturers and not to equipment manufacturers you are correct in your conclusion that these regulations are inapplicable to your client. We have proposed, however, that Part 573 be amended to apply to manufacturers of replacement equipment although no action has yet been taken on the proposal. I include a copy of that proposal.

You also asked about the applicability of Section 577.4 which you found to be "silent about the duty of manufacturers of motor vehicle equipment". The Part 577 that you referenced reflects the statutory scheme that was in effect until December 27, 1974, under which a manufacturer of motor vehicle equipment (as contrasted with a vehicle manufacturer who also produced equipment) was not required to notify purchasers of safety-related defects or noncompliances which it, the manufacturer, had discovered. The equipment manufacturer's obligation to notify arose only upon determination of the existence of a safety-related defect or noncompliance by the NHTSA Administrator and in that event Section 577.5 requires the equipment manufacturer to follow the provisions of Section 577.4. The new statutory scheme of 15 U.S.C. 1411 et seq., as reflected in revised Section 577.5, now extends the notification and remedy obligation to safety-related defects and noncompliances discovered by manufacturers of replacement equipment.

Finally, you have asked if there is no duty to retain records how can an equipment manufacturer "observe the requirements of Part 577.4." I assume what you mean is how can it notify "the first purchaser (where known) . . . and any subsequent purchaser to whom a warranty on such . . . item of equipment has been transferred". The actual obligation of a manufacturer of replacement equipment today, however, is that established by 15 U.S.C. 1413(c)(3)(A), in effect since December 27, 1974, and it is to notify "the most recent purchaser known to the manufacturer" (See also new Section 577.7(a)(2)(ii)(A). Congress appears to have recognized that manufacturers of small and less expensive items of motor vehicle equipment generally may not keep records of ultimate purchasers when it authorized our agency to issue a public notice when the public interest requires it (15 U.S.C. 1413(c)(3)(B)). Since there is no obligation for a manufacturer to know the names of its purchasers, NHTSA will accept in good faith an equipment manufacturer's statement as to the extent of its knowledge of its most recent purchasers. Under proposed Section 573.7(c) your client, as a manufacturer of motor vehicle equipment, would be required to maintain certain records including a list of the names and addresses of the "most recent purchasers known to the manufacturer". Such a list would probably at a minimum comprise distributors of the product, might also include the dealers of the distributors, and possibly in some instances the ultimate purchaser. But it is not a requirement that steps be taken to know and list the names and addresses of all ultimate purchasers. If you have further questions after reviewing this letter and its enclosures I will be happy to answer them for you.

ID: 9912

Mr. Fred Carr, Engineer
Utilimaster
65266 State Road 19
P. O. Box 585
Wakarusa, IN 46573-0585

Dear Mr. Carr:

This responds to your question asking whether Federal Motor Vehicle Safety Standard No. 211, Wheel nuts, wheel discs, and hub caps, applies to "motor vehicle equipment relating to light duty, medium duty, and heavy duty trucks or truck manufacturers." As explained below, Standard No. 211 does not apply to trucks, or truck equipment.

S2. Application of Standard No. 211 states the following:

This standard applies to passenger cars, multipurpose passenger vehicles, and passenger car and multipurpose passenger vehicle equipment.

"Multipurpose passenger vehicle" is defined at 49 CFR '571.3 as a motor vehicle designed to carry 10 persons or less, which is constructed either on a truck chassis or with special features for occasional off-road operation. Since Standard No. 211 applies only to passenger cars, multipurpose passenger vehicles, and their equipment, Standard No. 211 does not apply to trucks, or truck equipment. "Truck" is defined at 49 CFR '571.3 as a motor vehicle designed primarily for the transportation of property or special purpose equipment. Accordingly, manufacturers of trucks or truck equipment are not required to certify their trucks and truck equipment to the requirements of Standard No. 211.

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

Sincerely,

John Womack Acting Chief Counsel ref:211 d:5/16/94

ID: nht95-2.40

TYPE: INTERPRETATION-NHTSA

DATE: April 19, 1995

FROM: Carol Stroebel, Director -- Intergovernmental Affairs, NHTSA

TO: Honorable Tillie K. Fowler -- Member, U.S. House of Representatives

TITLE: Your Reference: 95-0167-J

ATTACHMT: ATTACHED TO 3/10/95 LETTER FROM TILLIE K. FOWLER TO RICARDO MARTINEZ; ALSO ATTACHED TO 1/4/95 LETTER FROM PHILIP RECHT TO FORBES HOWARD

TEXT: Dear Congresswoman Fowler:

Thank you for your letter on behalf of your constituent, Mr. Dail Taylor of St. Augustine, Florida. Mr. Taylor requested assistance, stating that his company would have to stop manufacturing passenger motor vehicles if the vehicles must meet the Federal Motor Vehicle Safety Standards (FMVSSs). I appreciate the concerns of Mr. Taylor as a small businessman and offer the following information.

In order to protect motorists and their passengers, a Federal statute requires the National Highway Traffic Safety Administration to issue FMVSSs regulating motor vehicles and motor vehicle equipment. Mr. Taylor's company, Goodlife Motor Company, wrote to NHTSA asking whether their "super golf cars" were motor vehicles and therefore subject to the FMVSSs. NHTSA's Chief Counsel responded by letter that the answer was "yes".

We were informed that the "super golf cars" are intended for use on public roads. NHTSA has two criteria for determining whether a vehicle that regularly uses the public roads is considered to be a "motor vehicle." A vehicle is not a motor vehicle if it meets both of the following criteria: the vehicle has an abnormal configuration distinguishing it from other vehicles; and the vehicle cannot attain speeds over 20 miles per hour (mph).

The "super golf cars" do not meet either criterion. We have determined that because the vehicles resemble passenger cars, they do not have an abnormal configuration. As to speed, we note that the top speed of the vehicles, 29 mph, is approximately the speed at which NHTSA conducts crash tests to see whether vehicles meet certain safety standards. It is also a speed at which vehicle occupants can readily suffer serious or even fatal injuries in a crash. We note further that older adults are more susc eptible than younger adults to injury in motor vehicle crashes. This is particularly important since we understand that one of the primary expected uses of the "super golf car" is in retirement communities.

As motor vehicles, the "super golf cars" must meet the FMVSS. As the president of a small business, Mr. Taylor has a number of compliance options. First, he can comply with the current safety standards. I appreciate that the costs of compliance would be significant. Second, Mr. Taylor may petition NHTSA to initiate rulemaking to amend the current safety standards to accommodate any special compliance problems that a small car might experience. NHTSA has authority to establish different levels of re quirements for vehicles of different sizes. However, it lacks the authority to vary the stringency of requirements based on the size of a vehicle manufacturer.

Third, NHTSA has authority to grant temporary exemptions to small manufacturers. Mr. Taylor may petition for a temporary exemption from one or more of the safety standards. However, as we explained to Mr. Taylor, temporary exemptions are primarily grant ed as an interim measure to give small manufacturers a chance to come into compliance. Further, the exemptions are typically given for only a select number of the standards applicable to an exempted vehicle. Across-the-board exemptions from all standard s have not been granted.

Mr. Taylor may himself prepare and submit any petition. We have enclosed copies of our regulations regarding petitions for rulemaking and petitions for exemption. If Mr. Taylor has any questions or needs further information on how to proceed under any of the three options discussed above, we will gladly provide assistance. Please ask him to contact Taylor Vinson at (202) 366-2992.

ID: 8753

The Honorable Tillie K. Fowler
Member, U.S. House of Representatives
4452 Hendricks Avenue
Jacksonville, FL 32207

Your Reference: 95-0167-J

Dear Congresswoman Fowler:

Thank you for your letter on behalf of your constituent, Mr. Dail Taylor of St. Augustine, Florida. Mr. Taylor requested assistance, stating that his company would have to stop manufacturing passenger motor vehicles if the vehicles must meet the Federal Motor Vehicle Safety Standards (FMVSSs). I appreciate the concerns of Mr. Taylor as a small businessman and offer the following information.

In order to protect motorists and their passengers, a Federal statute requires the National Highway Traffic Safety Administration to issue FMVSSs regulating motor vehicles and motor vehicle equipment. Mr. Taylor's company, Goodlife Motor Company, wrote to NHTSA asking whether their "super golf cars" were motor vehicles and therefore subject to the FMVSSs. NHTSA's Chief Counsel responded by letter that the answer was "yes".

We were informed that the "super golf cars" are intended for use on public roads. NHTSA has two criteria for determining whether a vehicle that regularly uses the public roads is considered to be a "motor vehicle." A vehicle is not a motor vehicle if it meets both of the following criteria: the vehicle has an abnormal configuration distinguishing it from other vehicles; and the vehicle cannot attain speeds over 20 miles per hour (mph).

The "super golf cars" do not meet either criterion. We have determined that because the vehicles resemble passenger cars, they do not have an abnormal configuration. As to speed, we note that the top speed of the vehicles, 29 mph, is approximately the speed at which NHTSA conducts crash tests to see whether vehicles meet certain safety standards. It is also a speed at which vehicle occupants can readily suffer serious or even fatal injuries in a crash. We note further that older adults are more susceptible than younger adults to injury in motor vehicle crashes. This is particularly important since we understand that one of the primary expected uses of the "super golf car" is in retirement communities.

As motor vehicles, the "super golf cars" must meet the FMVSS. As the president of a small business, Mr. Taylor has a number of compliance options. First, he can comply with the current safety standards. I appreciate that the costs of compliance would be significant. Second, Mr. Taylor may petition NHTSA to initiate rulemaking to amend the current safety standards to accommodate any special compliance problems that a small car might experience. NHTSA has authority to establish different levels of requirements for vehicles of different sizes. However, it lacks the authority to vary the stringency of requirements based on the size of a vehicle manufacturer.

Third, NHTSA has authority to grant temporary exemptions to small manufacturers. Mr. Taylor may petition for a temporary exemption from one or more of the safety standards. However, as we explained to Mr. Taylor, temporary exemptions are primarily granted as an interim measure to give small manufacturers a chance to come into compliance. Further, the exemptions are typically given for only a select number of the standards applicable to an exempted vehicle. Across- the-board exemptions from all standards have not been granted.

Mr. Taylor may himself prepare and submit any petition. We have enclosed copies of our regulations regarding petitions for rulemaking and petitions for exemption. If Mr. Taylor has any questions or needs further information on how to proceed under any of the three options discussed above, we will gladly provide assistance. Please ask him to contact Taylor Vinson at (202)366-2992.

Sincerely,

Carol Stroebel, Director Intergovernmental Affairs

Enclosures

ref:VSA d:4/19/95

ID: 19541.drn

Lisa Shalkowski, Director
Sunshine Child Care Center
1801 S.W. McKinley
Des Moines, IA 50315

Dear Ms. Shalkowski:

This responds to your letter concerning Federal school bus requirements that apply to the sale or lease of a 15-person van to your center. You state that the Sunshine Child Care Center is licensed to care for up to 120 children, about 20 of whom are of school age. You state that you have been trying to purchase a used van, and you also ask whether our school bus requirements apply. You write that "The majority of our van use would be for the purpose of transporting preschool age children to parks, libraries, and other special events" and that "[d]uring the school year, we transport school age children to and from the neighborhood school, which is only five blocks away."

By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue and enforce Federal motor vehicle safety standards applicable to new motor vehicles. Our statute at 49 U.S.C. 30112 requires any person selling or leasing a new vehicle to sell or lease a vehicle that meets all applicable standards. Accordingly, persons selling or leasing a new "school bus" must sell or lease a vehicle that meets the safety standards applicable to school buses. Our statute defines a "schoolbus" as any vehicle that is designed for carrying a driver and more than 10 passengers and which, NHTSA decides, is likely to be "used significantly" to transport "preprimary, primary, and secondary" students to or from school or related events. 49 U.S.C. 30125. By regulation, the capacity threshold for school buses corresponds to that of buses -- vehicles designed for carrying more than ten (10) persons. For example, a new 15-person van that is likely to be used significantly to transport students is a "school bus" and must meet our school bus safety standards.

Your letter did not provide much information on the use of the van, but it appears that use of it to carry students to or from school may be "significant." Your daily and regular use of the van to carry students to and from school is similar to use of a van described in our July 23, 1998 letter to Northside Ford (copy enclosed). That letter addressed the use of a van by a child care facility to transport children to or from school "on regular school days." NHTSA stated that: "Such recurring and consistent use of the van to transport students 'to or from school' would constitute a 'significant' use of the vehicle."

The requirement to sell or lease complying school buses applies only to new buses. If the Sunshine Child Care Center wishes to buy a used 15-person van or enter into a long-term lease of such a bus, that transaction is not regulated by NHTSA. However, using buses that do not meet the school bus standards to transport students could result in increased liability in the event of a crash. Since such liability would be determined by State law, you may wish to consult with your attorney and insurance carrier for advice on this issue.

I hope this information is helpful. For more information about the safety features of a school bus, I am enclosing NHTSA's publication: "School Bus Safety: Safe Passage for America's Children." I am also enclosing NHTSA's Februrary 1999 "Guideline for the Safe Transportation of Pre-school Age Children in School Buses." If you have any further questions please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref:VSA#571.3
d.4/7/99