ID: aiam0446

Dear Mr. Gerth: This is in reply to your letter of August 20, 1971, in which you aske whether the shoulder belt anchorages installed by Mercedes in its heavy trucks (over 10,000 GVWR) must meet the strength requirements of Standard No. 210, even though the standard does not require shoulder belt anchorages in vehicles over 10,000 pounds GVWR.; It is our opinion that because these anchorages are not required to b installed, they are not required to meet the strength requirements of Standard No. 210. You may therefore continue to use plastic covers on the anchorages and need not render them unusable.; Please advise us if you have further questions. Sincerely, Lawrence R. Schneider, Chief Counsel

ID: nht92-8.6

DATE: April 3, 1992

FROM: Herr Spingler -- Entwicklung Lichttechnik Systeme, Robert Bosch GmbH

TO: Richard van Iderstine -- Office of Rulemaking, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/29/92 from Paul J. Rice to Herr Spingler (A39; Std. 108)

TEXT:

For a new Porsche-car, we have decided to develop a headlamp as shown in the attached drawing. The lowbeam will be provided by an ellipsoid, the highbeam by a parabola. When highbeam is on, both bulbs will be on simultaneonsly.

My question is:

Will this headlamp meet the FMVSS-108-requirements concerning the location on a car?

Thanks in advance for a quick answer.

ID: nht93-2.14

DATE: March 11, 1993

FROM: Samuel Kimmelman

TO: Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3-31-93 from John Womack to Samuel Kimmelman (A41; Std. 108); Also attached to letter dated 11-1-89 from Stephen P. Wood to Samuel Kimmelman

TEXT: Enclosed is a copy of a letter dated Nov. 1, 1989 from NHTSA, signed by the then Acting Chief Counsel Stephen P. Wood.

In the next to last paragraph Mr. Wood states that NHTSA requires the front hazard waning lamps must continue to operate even when the stop lamps are activated.

Does NHTSA continue to hold to the requirement as put forth in Mr. Wood's letter or has this requirement been revised?

ID: aiam1558

Dear Mr. Spretnjak: This is in reply to your letter of June 28, 1974, requesting the statu of a proposed amendment published January 9, 1971 (36 F.R. 327), to Motor Vehicle Safety Standard No. 205, 'Glazing Materials,' that would have required markings specified for windshields to appear in each windshield's lower left-hand corner.; This proposed requirement was not adopted. Other requirements propose by this notice, however, were adopted by a subsequent notice published June 21, 1972 (37 F.R. 12237), which amended Standard No. 205. The preamble of this notice referred to the agency's action on the proposed requirements for marking location. A further notice was issued on November 11, 1972 (37 F.R. 24035), which responded to petitions for reconsideration of the amendments of June 21, 1972. Copies of the notices of June 21 and November 11, 1972, are enclosed.; There are presently no requirements regarding the location of marking for motor vehicle glazing materials.; Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: nht91-5.20

DATE: August 9, 1991

FROM: David L. Kulp -- Manager, Fuel Economy Planning & Compliance, Environmental and Safety Engineering Staff, Ford Motor Company

TO: Orron E. Kee -- NHTSA

TITLE: Reference: Deletion of Off-Highway Data from the Pre-Model and Mid-Model Reports

ATTACHMT: Attached to letter dated 10-23-91 from Paul Jackson Rice to David L. Kulp (A38; Part 523; Part 537)

TEXT:

Ford requests your concurrence to discontinue the reporting of off-highway data as listed in S537.7(c)(5) for light-duty trucks that otherwise comply to the light-duty truck definition in S523.5(a). Per a telephone conversation between you and Ms. Peg Gutmann of my staff on July 19, 1991, the off-highway data is only required for automobiles that a manufacturer wishes to classify as a light-duty truck per the provisions of S523.5(b).

Please contact Ms. Gutmann at (313) 337-5367 if you have any questions or concerns.

ID: aiam0113

Dear Mr. Heath: Your letter of August 19, 1968, addressed to Mr. David A. Fay, of th National Highway Safety Bureau has been forwarded to my office for reply.; The original list of definitions of vehicles was published in th Federal Register as part of a Notice of Proposed Rule Making dated December 3, 1966. Comments were requested from interested parties. Subsequently, the definition of a multipurpose vehicle was added to the Federal Motor Vehicle Safety Standards in response to a number of comments received from industry requesting a different category for certain utility vehicles. Under the previous classification, there were a number of special purpose vehicles which did not fit into any single category. It was agreed that certain types of motor vehicles, such as Dune Buggies, the Carryall, Travelall, Compact Van, Jeep Wagoneer, Ford Bronco, and Scout type vehicles comprised a hybid (sic) class of motor vehicle which possessed the characteristics of more than one of the motor vehicle categories previously established. The 'special features' include such items as 4-wheel drive amphibious equipment. Due to the differences in body construction, load time requirements, and general vehicle purpose, it was not considered reasonable to require those dual purpose vehicles designed to carry ten persons or less to meet all of the passenger car requirements, as would have been required by the Notice. For those reasons, the new category of 'multipurpose passenger vehicle' use (sic) added to Section 245(b).; Your interest in the automotive safety program of the Federal Highwa Administration is greatly appreciated.; Sincerely, Eugene B. Laskin, Acting Director, Office of Standard Preparation, Motor Vehicle Safety Performance Service;

ID: aiam3284

Dear Mr. Kneip: This is in response to your letter of May 7, 1980, in which you aske whether the proposed Nebraska certificate of title may be used as a substitute for the Federal odometer disclosure form required by 49 CFR Part 580.; The Nebraska title differs from the minimum Federal requirements i that there is no certification that the odometer reading reflects the actual mileage or the mileage over 99,999 miles, or is not the actual mileage. The buyer is not required to sign the Nebraska title as he is the Federal form (sic). In addition, your title does not refer to the legal consequences of a false disclosure. If you can make these additions, the Nebraska title will satisfy the Federal requirements.; For your information, I have enclosed a copy of the *Federal Register notice which discusses the short form odometer disclosure that States may use on their titles to satisfy Federal requirements, a letter to Maryland in which we indicate that formal approval by NHTSA is not necessary if the title contains the specified information, and sample titles that the NHTSA has approved.; If you need any further inforamtion, please do not hesitate to contac us.; Sincerely, John Womack, Assistant Chief Counsel

ID: aiam1415

Dear Mr. Hespeler:#This is in reply to your letter of January 21, 1974 which requested interpretation of Federal Motor Vehicle Safety Standard No. 104, 'Windshield Wiping and Washing Systems.'#The wiped area as stated in S4.1.2, is to be evaluated as a percentage of areas A, B, and C 'of the windshield.' This means that areas A, B, and C are evaluated in 'unwrapped view,' rather than in the form of a projection of the windshield's surface.#Sincerely, E.T. Driver, Director, Office of Operating Systems, Motor Vehicle Programs;

ID: aiam3767

Dear Mr. Mandell: This is in response to your letter of October 19, 1983, discussing lighting product that you have developed and asking for 'the approval of the DOT or at least to insure that no active disapproval would be forthcoming.'; Your device utilizes the body panel between the left and right rea lights to emphasize braking, right and left turns, hazard flashing, and backing up. Roughly, your device operates by lights spreading from the center of the panel outward, in either or both directions.; We think that there is great potential for confusion that this devic could create since it is so unlike anything seen before on a motor vehicle. In the stopping mode the driver following will see the steady light of the stop lamp at the edge of the vehicle, but also the dynamic lights of your device spreading out from the center. The same dynamic light spread is seen but is meant to indicate something entirely different when both turn signal lamps are operating simultaneously in the hazard warning mode. Thus, the potential for impairment of the required lighting equipment exists.; Generally, we do not favor any lights on the rear of a vehicle that ar not required by the Federal lighting standard.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam0260

Dear Mr. Lundstrom: This is in reply to your letter to Mr. Toms of October 15, 1970, i which you asked whether General Motors could provide one consumer information document to fleet purchasers of motor vehicles, rather than putting a booklet in each car as is done in the usual case.; The answer is yes. 49 CFR 575.6(a) requires that the information b provided 'to that purchaser', 'at the time a motor vehicle is delivered' to him. It does not require that the information be in the vehicle, or that there be one booklet per vehicle.; We are pleased to be of assistance. Sincerely, Rodolfo A. Diaz, Acting Associate Director, Motor Vehicl Programs;