ID: nht88-1.69

TYPE: INTERPRETATION-NHTSA

DATE: 03/14/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mercedes-Benz of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Karl-Heinz Faber Vice President Product Compliance and Service Mercedes-Benz of North America, Inc. P.O. box 350 Montvale, NJ 07645

Dear Mr. Faber:

Thank you for your letter concerning the requirements of Standard No. 210, Seat Belt Assembly Anchorages. In particular, you asked for an interpretation of the provisions of S4.3 of the standard. I regret the delay in answering your questions.

S4.3 of Standard No. 210 provides, in part, that "Anchorages for automatic and for dynamically tested seat belt assemblies that meet the frontal crash protection requirements of S5.1 of Standard No. 208 (49 CFR Part 571.208) are exempt from the location requirements of this section." (Emphasis added.) You first asked the agency to confirm that anchorages to be used with automatic and dynamically tested safety belts that meet the requirements of S5.1 of Standard No. 208 are exempt from all of the anchora ge location requirements of S4.3. You are correct that S4.3 of Standard No. 210 provides that such anchorages are exempt from all the location requirements.

The amendment to exempt anchorages of dynamically tested seat belt assemblies from the anchorage location requirements of Standard No. 210 became effective on May 5, 1986, well in advance of the September 1, 1989 effective date for dynamic testing of man ual belts. This effective date indicates that the agency did not intend to limit the exemption from the anchorage location requirements to manual safety belts that were required to be dynamically tested. Additionally, the exemption applies to dynamically tested seat belt assemblies that "meet" the frontal crash protection requirements of Standard No. 208, rather than to vehicles "subject to" the frontal crash protection requirements of that Standard. This language indicates that NHTSA intended to allow manufacturers to take advantage of the exemption from the anchorage location requirements for dynamically tested safety belts before the dynamic testing requirements were applicable to such belts. Accordingly, if a vehicle is equipped with a manual safet y belt at either or both front outboard seating positions, and the anchorage or anchorages for those belts do not comply with the anchorage location requirements set forth in S4.3 of Standard No. 210, the manufacturer must certify that the belts attached at any such anchorage points comply with 55.1 of Standard No. 208.

In your second question, you asked the following:

We also understand that such dynamic testing may be combined with other compliance testing, and the vehicle or vehicles used may be equipped "as delivered" for sale to a consumer. Accordingly, the vehicle structure with built-in energy management feature s, seats with designed-in anti-submarining construction, energy absorbing instrument panel, collapsible steering column, driver and/or passenger airbag(s), anti-lacerative windshield glass, emergency tensioning retractors, etc. may be installed and funct ional, where applicable, during the compliance crash test.

During its compliance testing, NHTSA combines a test of the occupant crash protection capabilities of automatic or manual safety belts with testing done to determine compliance with other standards. The agency tests vehicles to the frontal barrier crash requirements of Standard Nos. 208, 212, 219, and 301 in a single barrier impact. In conducting these compliance tests, NHTSA tests vehicles in their "as delivered" form with all items of standard equipment present in the vehicle. Thus, if a vehicle has d evices, such as an air bag system or pre-tensioning devices for the belts, installed in the vehicle as items of standard equipment, NHTSA's compliance testing is conducted with those items in place and fully functioning. If our compliance testing shows t hat a vehicle tested with a manual safety belt at one or both front outboard seating positions complies with the occupant crash protection requirements of S5.1 of Standard No. 208, then the anchorages for the belt or belts would not be subject to the anc horage location requirements of S4.3 of Standard No. 210.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

April 20, 1987

Ms. Erica Z. Jones, Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC. 20590

Subject: Request for Interpretation Concerning FMVSS-210

Dear Ms. Jones: Mercedes-Benz of North America, Inc.(MBNA) requests an interpretation of FMVSS-2IC "Seat Belt Assembly Anchorages-Passenger Cars, Multi-Purpose Passenger Vehicles, Trucks, and Buses". Paragraph S4.3 Location states, "Anchorages for automatic and for dyna mically tested seat belt assemblies that meet the frontal crash protection requirements of S5.1 of Standard No. 208 (49 CFR Part 571.208) are exempt from the location requirements of this section."

MBNA interprets the foregoing provision to mean that all of the anchorage location requirements under paragraph S4.3 (i.e. S 4.3.1, S 4.3.1.1, S 4.3.1.2, S 4.3.1.3, S 4.3.1.4, and S 4.3.2) are not applicable to seat belt assemblies which have been dynami cally tested via a vehicle crash test and meet the occupant protection criteria described in S5.1 of Standard No. 208. We also understand that such dynamic testing may be combined with other compliance testing, and the vehicle or vehicles used may be equ ipped "as delivered" for sale to a consumer. Accordingly, the vehicle structure with built-in energy management features, seats with designed-in anti-submarining construction, energy absorbing instrument panel, collapsible steering column, driver and/or passenger airbag(s), anti-lacerative windshield glass: emergency tensioning retractors , etc. may be installed and functional, where applicable, during the compliance crash test.

Ms. Erika Z. Jones Request for Interpretation Concerning FMVSS-210

The basis for our interpretation is set forth in the Agency's preamble comments to MVSS-208 (Part 571; S208-PRE28B) concerning mandatory dynamic testing where the preamble provides that ". . . the (dynamic testing) standard will assure that the vehicle's structure, safety belts, steering column, etc., perform as a unit to protect occupants, as it is only in such a test that the synergistic and combination effects of these vehicle components can be measured". This factor when coupled with the Agency's st atement that the best way to measure the performance of the safety belt/vehicle combination is through a vehicle crash test" fully supports our interpretation.

Accordingly, we would request that you confirm our interpretation that, during dynamic testing of seat belts, the vehicle should be equipped and functional as closely as possible to a new vehicle which would be sold to the consumer, and that such testing supplants the requirements of 54.3

Thank you in advance for your response.

Sincerely,

ID: nht88-1.7

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/88 (EST)

FROM: PAUL RENEAU

TO: U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/26/88 TO PAUL A. RENEAU FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 118

TEXT: Dear Engineer:

Would you please review the following information and inform me as to whether the design of the power-operated window system described and specified meets rule no. 118, titled "Power-Operated Window Systems" as amended in 1983.

SPECIFICATION: As per rule no. 118, S1 in the schematic corresponds to the ignition key switch. S1 is closed in the "ON" or "ACCESSORY" position. Closing S1 activates transistor Q1 which deactivates transistor Q2. Q2 supplies voltage/current to transi stors Q3 and Q4. Q3 drives power relay K1 and Q4 drives power relay K2. Both relays have normally open contacts which supply voltage to drive electric window and/or partition motors. With S1 in the "ON" or "ACCESSORY" position, normal power window and /or partition function exists. When the key that controls S1 is returned to the "OFF" position, Q1 is deactivated after capacitor C1 discharges through resistor R1 for a time period determined by RC timing circuit; D1, C1, R1 and Q1. Q2 is activated upo n deactivation of Q1 and supplies voltage/current to Q3 and Q4. Q3 is driven by RC timing circuit; C2, R3 for a time period determined by the values of C2 and R3. Q3, as stated, drives normally-open relay K1 which in turn drives electric motor M1. Q4 operates in a similar manner driving motor M2. Upon deactivation of Q3 and Q4, relays K1 and K2, and consequently, motors M1 and M2 are deactivated. With R3 and R4 as potentiometers, the corresponding motor activation can be adjusted for only as long a s required to close the said window and/or partition. S2 is closed when either front door is opened. This switch (es) corresponds to switches currently used on vehicle door posts to activate interior/courtesy lights and the door-ajar indicator. These switches are widely used and proven reliable in the industry. Opening either front door closes switch S2 and short circuits the RC timing circuits driving K1 and K2 thus instantaneously stopping motors M1 and M2. The said circuits are reactivated ONLY by closing S1 which requires that the key be in the ignition and in the "ON" or "ACCESSORY" position. This insures that the driver would almost certainly have to be in the vehicle.

2

SPECIFICATION cont.

In the event that a door is opened while the ignition key is in the "ON" or "ACCESSORY" position, the RC timing circuit supplying Q3 and Q4 are shorted. If both front doors are not closed prior to returning the ignition key to the "OFF" position, the sy stem remains totally deactivated. It should be noted that in addition to the requirements of the NHTSA, this system also employs an "OFF/ON" switch which is easily accessible to the driver. This switch is not shown on the schematic, however, it supplie s ground to the system, and must be in the "ON" position prior to turning the ignition key from the "ON" or "ACCESSORY" position to "OFF" in order to activate the system. This switch allows the system to be turned off when it is not needed (cold weather ) or if the ignition key switch is not used to deactivate the system.

It is understood that component electrical ratings must be maintained as in any electrical device.

If you have any questions or require further information, please contact me.

Thank you for you time and promptness in reviewing this matter.

ENCLOSURE

(DIAGRAM OMITTED)

ID: nht88-1.70

TYPE: INTERPRETATION-NHTSA

DATE: MARCH 15, 1988

FROM: CARL C. CLARK -- INVENTOR CONTACT, NHTSA

TO: CLAIRE HAVEN--QUADWEST, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 11-22-88 TO CLAIRE HAVEN, QUADWEST, FROM ERICKA Z. JONES, NHTSA; REDBOOK A33; STDS. 209, 208, 302; VSA108 (A)(2)

TEXT: Thank you for sending your "Joyride" Seatbelt Pad, which you propose to sell as a comfort rather than a safety feature. This nylon covered foam pad device fits inside of the shoulder belt and is attached to the shoulder belt by nylon babs running the le ngth of the pad (about 16 inches) with velcro along the entire length. You have asked for my comments on its design prior to your writing to Ms. Erika Jones, Chief Counsel of this agency, for a formal letter as to whether the device would be expected to take a shoulder belt out of compliance with any applicable Federal Motor Vehicle Safety Standard.

The pad has a thickness of about one inch of moderately soft foam, sufficient to spread the load of the retractor force over its width of about 3.5 inches but not sufficient to spread the load under crash conditions, which would require a much stiffer pa d. In the model sent to me, the nylon tabs were closer together than the one and seven eights inches width of the belt, and so did not wrap around the belt to allow complete overlapping of the velcro. You advised me that this was an early model and lat er models had the proper clearance for the belt. Once the pad is in place from the shoulder across the chest, it does make the belt a little more comfortable, particularly if the retractor has a continuous pull, without the "windowshade" feature.

On getting out of the car, the pad must either be removed from the belt or slid toward the latch plate, or it prevents the retractor from reeling up the belt completely or in part, so that the belt may become tangled and less easy to use on the next entr y. We have tried the pad with an automatic motorized passive belt, which has a motor that moves the belt along a track around the door when the door is closed, automatically positioning the shoulder belt across the body; since the retractor is near the center of the car, the pad simply slid along the belt and caused no jamming.

When the pad is in place, it does introduce a slight amount of additional shoulder belt length, but within the one inch or so of acceptable slack, expectedly similar to wearing a coat under a belt.

We do not provide certification tests for showing compliance with standards, nor do we endorse products. A manufacturer, in selling an automotive product, is by the National Traffic and Motor Vehicle Safety Act "self-certifying" that the product meets a ll aplicable federal safety standards. Your product is used in association with the belts, covered under Federal Motor Vehicle Safety Standards 208 and 209, but such a product is not specifically mentioned in these standards. Your device, if left on th e shoulder belt, retards or inhibits retraction, and so may inhibit subsequent belt use if the belt becomes tangled. But for those troubled by the slight retractor load on the shoulder (in some car models), the pad would expectedly increase the comfort o f using the belt. And for short people for whom the shoulder belt may rest flat on the neck, your pad may provide sufficient stiffness to hold the shoulder belt on the shoulder rather than on the neck, a potential safety benefit.

I see no technical safety objection to its use, but you should also request the formal review by the Chief Counsel as to whether there is any implication of interference of your device with an applicable standard.

ID: nht88-1.71

TYPE: INTERPRETATION-NHTSA

DATE: 03/16/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Koito Mfg. Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. M. Iwase Technical Administration Dept. Roito Mfg. Co. Ltd. Shizuoka Works 500, Ritawaki Shimuzi--shi, Shizuoka-ken JAPAN

Dear Mr. Iwase:

This is in reply to your letter of January 25, 1988, with respect to photometric values for stop lamps and taillamps on motorcycles, and the spacing required between them and turn signal lamps.

You have asked two questions with respect to two types of motorcycle rear lighting devices, which you call "Structure 1" and "Structure 2". Although a single lamp located on the vertical centerline may be used to fulfill rear lighting requirements on mot orcycles, each of your Structures features two bulbs, symmetrically placed on each side of the vertical centerline. Each Structure is a single lighting device, featuring a turn signal bulb at each extremity. In Structure 1 a chamber containing a tail/sto p lamp bulb is directly inboard of the chamber containing a turn signal bulb. The two chambers on each side are separated by a central portion of the device which is decorative in nature. Unlike Structure 1, Structure 2 is a three-chamber device, with se parate chambers at each end for the turn signal bulbs, and a central chamber incorporating two tail/stop lamp bulbs.

With respect to each Structure and Motor Vehicle Safety Standard No. 108 you have asked:

"(a) When tail & stop lamp on either side is lighted individually, it shall be satisfied with the photometric values of lighted section "1" which are specified in Figure 1b of S4.1.1.11.

(b) When tail & stop lamp on both sides are lighted together, it shall be satisfied with the photometric values of lighted section "2" which are specified in figure 1b of S4.1.1.11." Figure 1b specifies the minimum and maximum allowable candlepower values for lighting devices with one, two, and three lighted sections. However, the number of lighted sections is calculated with respect to each lamp, not the total number of lighted sect ions used for a specific purpose, or lit at a given time. We consider Structure 1 to comprise two separate tail/stop lamps, each consisting of a single chamber. Similarly, Structure 2 incorporates a single tail/stop lamp consisting of a single chamber in which two bulbs are used. Therefore, for both Structures and for both (a) and (b) the lamp should be designed so that the single chambers meet the photometric values for single compartment lamps.

Your second question for each Structure is whether the specified minimum edge to edge separation distance between turn signals and tail/stop lamps is required. The answer is yes, and the separation distance you have depicted in your drawings appears to c omply with this requirement.

Sincerely,

Erika Z. Jones Chief Counsel

Air-Mail

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

Subject: Tail & Stop Lamp for Motorcycle (1) photometric values (2) Spacing with Turn Signal Lamp

Dear Ms. Erika Z. Jones:

The photometric values which are required for tail & stop lamp for motorcycle are specified in S. 4.1.1.11 of FMVSS No. 108, and minimum spacing between the lamp and turn signal lamp is specified in Table IV.

We would like to ask you the following questions concerning photometric values of tail g stop lamp for motorcycle and minimum spacing between the lamp and turn signal lamp in the cases of Structure-(1) and -(2) which are shown in the attached drawing.

Question-1:

In Structure-(1) and -(2), which of the following cases shall be applied for the photometric values required for tail & stop lamp?

(a) When tail & stop lamp on either side is lighted individually, it shall be satisfied with the photometric values of lighted section "1" which are specified in Figure lb of S. 4.1.1.11.

(b) When tail & stop lamps on both sides are lighted together, it shall be satisfied with the photo-metric values of lighted section "2" which are specified in figure 1b of S. 4.1.1.11.

Attn: Ms. Erika Z. Jones Date: Jan. 25, 1988

Question-2; For each case of Structure-(1) and-(2) as illustrated in the attached sheet, shall the specification of 4 inch minimum spacing between tail & stop lamp and turn signal lamp be required or not:

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

Very truly yours,

Mr. Iwase Manager Technical Administration Dept. Koito Mfg. Co., Ltd. Shizuoka Works

(SEE ATTACHMENT...)

ID: nht88-1.72

TYPE: INTERPRETATION-NHTSA

DATE: 03/16/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: C.I. Nielsen -- Vice President, General Sales Manager, Wesbar Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. C. I. Nielsen Vice President General Sales Manager Wesbar Corporation P.O. BOX 577 West Bend, WI 53095

This is in reply to your letter of February 17, 1988, asking for an interpretation of paragraph S4.1.1.7 of Motor Vehicle Safety Standard No. 108, which applies to turn signal lamps. In pertinent part this section requires turn signal lamps for vehicles whose overall width is 80 inches or more to "have an effective projected luminous area not less than 12 square inches." Your design has a lens area of 12 square inches incorporating an integral Class A reflex reflector, and you have asked whether you may include the "illuminated (by the turn signal bulb) reflex reflector portion of the turn signal lens" in your calculation.

We assume from your letter that the light shines through the reflector when the turn signal is activated, and that the reflector is not opaque. In this instance, the reflector area may be included as part of "the effective projected luminous area" within the meaning of S4.1.1.7.

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

February 17, 1988

Ms. Erika Jones, Chief Counsel-DOT Room 5219 NASSIf Building 400 7th Street, Southwest Washington, DC 20590

SUBJECT: REQUEST FOR COMPLIANCE INTERPRETATION 54.1.1.7

Dear Ms. Jones:

We are writing to you for clarification of 54.1.1.7 of FMVSS 108. Our request involves turn signal lamps on trailers 80-inches or more in width and, practically speaking, centers around the wording "shall have an effective project luminous area not less than 12 square inches".

Our design calls for a multifunction lens of 12 square inches, which incorporates an integral Class A reflex reflector. QUESTION: When the turn lamp is activated, may we include, for the square inch calculation, the illuminated (by the turn signal bulb) reflex reflector portion of the turn signal lens: We know we are allowed to optically combine two, or more, functions (except for the tail light with the clearance light function), therefore, we don't see this concept as the hurdle. Instead, we find the question lying with the definition of "effective projected luminous area".

Thank you for looking into this matter, Ms. Jones, and we look forward to receiving your written interpretation on the "effective projected luminous area".

Respectfully,

WESBAR CORPORATION

C.I. NIELSON III Vice President General Sales Manager

CIN:mm cc: J. Karrenbauer S. Johnston A. Cunningham DOT

(SEE ATTACHMENT...)

ID: nht88-1.74

TYPE: INTERPRETATION-NHTSA

DATE: 03/16/88 EST

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: MORRIS EAST -- ASSISTANT DIRECTOR, LOUISIANA BUREAU OF SCHOOL TRANSPORTATION

TITLE: NONE

ATTACHMT: JULY 7, 1987 LETTER FROM EAST TO JONES IS ATTACHED

TEXT: This letter responds to your request for an interpretation of certain Federal motor vehicle safety standards that apply to school buses. I apologize for the delay in this response. In your letter, you state that one of your local school systems intends to remove a bus body from "an existing chassis, and place that body onto a new chassis." You state further that the system's school bus maintenance shop would perform the work. You ask a number of questions which I shall answer in order. My answers as sume that, at a minimum, the engine, drive axles, and transmission of the new chassis are new components.

Question 1: Is it permissible under the (Vehicle Safety Act as amended) for a local school board to remove the body from one school bus chassis and place that body on another school bus chassis?

The answer to this question is "yes." The Act does not prohibit a vehicle owner from altering, modifying, or manufacturing a vehicle; nor has NHTSA established such a prohibition in its regulations.

Question 2: Would this action (in Question 1) violate bus body integrity requirements of Federal Motor Vehicle Safety Standards (FMVSS) (specifically FMVSS 208, 220, 221)?

The act of removing a school bus body from one chassis and placing that body on a different chassis does not violate any Federal safety standard. However, when a person uses a new body and mixed new and used chassis components in refurbishing a vehicle, the question arises whether the vehicle is new. In past interpretations, NHTSA has applied @ 571.7(e) to school buses that combine a new body and either (1) mixed new and used chassis components, or (2) used chassis components from different vehicles. If a school bus is considered "new" under the criteria set out in this provision, then the person who refurbishes the vehicle must

certify that the school bus meets all applicable safety standards in effect on the date the chassis was manufactured - including Standards 208, 220, and 221 if they apply - and affix a certification label under 49 CFR Part 567.

On the other hand, if an old bus body is placed on a chassis that is completely new, a different provision applies. In this case, the chassis is an incomplete vehicle. "Incomplete vehicle" is defined in 49 CFR @ 568.3 as: an assemblage consisting, as a minimum, of a frame and chassis structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the ad dition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed vehicle.

When a new bus chassis meets this description, a subsequent person who adds a body - even an old body - is a final-stage manufacturer, and must certify the completed vehicle as conforming to all applicable Federal Motor Vehicle Safety Standards as of a d ate no earlier than the manufacturing date of the incomplete vehicle (the new chassis). (49 CFR @ 567.5, Requirements for Manufacturers of Vehicles Manufactured in Two or More Stages.)

Neither @ 571.7(e) nor Part 568 would require a person to recertify a school bus when the body and all other vehicle components are not new.

Question 3: If permitted, can the work described in (Question) 1. above be performed in the school board's maintenance shop? Can it be contracted to an automobile dealer capable of performing such work? Can the work be contracted to other motor vehi cle repair shops such as body dealers or private motor vehicle repair shops?

The answer to each of these statements is "yes." Remember, though, that if the refurbished buses are considered new under the criteria discussed in Question 2, they must meet all applicable school bus safety standards in effect on the date of manufacture , and a certification label must be affixed to each refurbished vehicle to that effect.

If the refurbished buses are not "new" under these same criteria, then there is no obligation to recertify the vehicles. However, if a manufacturer, dealer, distributor, or motor vehicle repair business works on your buses, then there is restriction on what these commercial businesses can do - even if the vehicle is used. Section 108(a)(2)(A) of the Vehicle Safety Act prohibits these persons from "knowingly rendering inoperative" any device or element of design incorporated into the vehicle in complia nce with an applicable Federal safety standard. Note that this restriction does not apply when the vehicle owner (e.g., a local school system) makes a modification, or if a repair facility that does not hold itself out to the public as being in the busi ness of motor vehicle repair (e.g., a maintenance shop that works only for the school board) makes the modification.

Question 4: If the changeover is allowed, must the new unit (new chassis with used body) be re-certified to meet FMVSS requirements? If it must be re-certified, who may provide the inspection and re-certification?

As I stated in my answers to Questions 2 and 3, under certain circumstances, the vehicle must be recertified by the refurbisher. The refurbisher is responsible for the vehicle's compliance status just as any vehicle manufacturer, and must be able to sho w that he exercised due care in certifying the vehicle. The agency examines issues of due care on a case-by-case basis evaluating all relevant facts. This evaluation would include assessing technological limitations, availability of test equipment, the market position of the manufacturer, and most importantly, the degree of manufacturer diligence.

I hope you find this information helpful.

ID: nht92-6.19

DATE: June 2, 1992

FROM: Jeffrey Puentes -- President, Sacramento Registration Service

TO: Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 6/30/92 from Paul J. Rice to Jeffrey Puentes (A39; Part 567; VSA Sec 102(3))

TEXT:

We are the agents for a client who would like to sell kits to the retail public.

What is your definition of a Kit Car? How far into the manufacturing process can a party assemble a kit before it is classified as an automobile?

What definitions and/or rules (laws) must he follow in order to begin selling kits for kit cars to the retail public?

If you should have any questions or concerns regarding this letter, please feel free to contact us here at the below listed numbers.

We thank you for your time and attention to this matter. We look forward to hearing from you.

ID: nht92-6.2

DATE: June 22, 1992

FROM: Trevor J. Buttle -- Project P4

TO: Office of Chief Council, U.S. DOT

TITLE: Our Ref 1547; Your Fax No. 0101 202 366 2106; Re: FMVSS 102, Transmission Lever Shift Sequences

ATTACHMT: Attached to letter dated 8/1/92 (est) from Paul J. Rice to Trevor Buttle (A39; Std. 101; Std. 102)

TEXT:

I am responsible for certification of a passenger vehicle being developed with a view to U.S.A. export in 2-3 years.

Could you please advise on the following concern relating to S3.1.4 of the above standard:

o The (transmission shift lever position) information is to be "displayed in view of the driver". - S3.1.4.1. I believe this relates to the 95% eye range contour, hence requiring a display on or near to the instrument binacle. Is this correct, or (as seems to be the current practice for some auto makers) is the floor shift identification sufficient? This query relates to auto and manual transmission.

o Could you also clarify whether the display should be permanently illuminated for night usage (again, some auto makers have opted to make this facility switchable).

Your assistance with these issues would be greatly appreciated.

ID: nht92-6.20

DATE: June 2, 1992

FROM: John Tanner -- U.S. House of Representatives

TO: John A. Cline -- Director, U.S. DOT, Congressional Liaison

TITLE: None

ATTACHMT: Attached to letter dated 6/29/92 from Frederick H. Grubbe to John Tanner (A39; Part 571.3)

TEXT:

Enclosed are copies of letters I received from school systems in Tennessee who are opposed to the National Highway Traffic Safety Administration's regulations against the use of 11-plus passenger vans to transport students. Our office has been in contact with Dr. Ernest Farmer, Director of Pupil Transportation at the Tennessee Department of Education about this matter.

It is my understanding that Dr. Farmer sent memos to our school systems in 1977 and 1990 about the NHTSA regulations. I respectfully request that you review their concerns and give to them your utmost consideration. Any information on the possibility of amending these regulations would be helpful so that I may respond to these constituents. Your cooperation is greatly appreciated.

Attachments

Letters from:

Johnny Williams, Principal, North Side Junior High School, Jackson, Tennessee Sam Miles, Principal, Peabody High School, Trenton, Tennessee Jackie Vaughan, Principal, Greenfield High School, Greenfield, Tennessee Farris Lowery, Huntingdon High School, Huntingdon, Tennessee Chuck West, Principal, Dresden High School, Dresden, Tennessee Mr. Ward, Principal, Crockett County High School, Alamo, Tennessee

Text of the form letter:

Dear Legislator:

Recently throughout our state much concern has mounted in regard to recent memos from Mr. Ernest Farmer, Director of Pupil Transportation, Tennessee State Department of Education. These memos have directed attention to an early 1970's federal law pertaining to use of vehicles with a capacity of eleven (11) or greater.

Over the years, many schools throughout the state have made use of 12 and 15 passenger vans to transport athletic teams and other school groups to and from school related event. These vans are NOT used for "pick-up" and "drops" on public roadways. Now, many systems have either had to park their vans or they are under a deadline to do so. This action already has or will create a tremendous financial burden on schools already strapped with financial hardships due to budget cuts. We fear the ultimate result will be the elimination of certain athletic teams and other school functions simply due to

the enormous expense involved in renting buses on a daily basis. Also, another tremendous problem is that of finding buses available at the time of day needed.

We desperately need your help in seeing that this law is amended or changed in order to permit the use of these vehicles. To insure that vans are maintained in a safe condition, they can be required to have the same inspection as that imposed on regular school buses.

We have real problems with a law that states we can legally use a van equipped to transport 10 passengers but we cannot use a van equipped to transport 11, 12 or 15 passengers. We do not understand the rationale in allowing a van to transport 10 passengers, but not 11, 12 or 15. We appreciate your concern in this matter and desperately need your support.

ID: nht92-6.21

DATE: June 2, 1992

FROM: Jeffrey Puentes -- President, Sacramento Registration Service

TO: Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7/13/92 from Paul J. Rice to Jeffrey Puentes (A39; Std. 115; VSA 102(4))

TEXT:

We are agents for a client who is interested in manufacturing and selling to the retail public motorcycle frames.

These frames will be used to replace various types of damaged Harley Davidsons, whether they be burned, crashed, or whatever.

What federal laws must he recognize and adhere to?

Regarding serial numbers - how will frame numbers be properly identified?

What, if any, rules must he abide by and use in order to begin this type of a retail business?

Also, please note that these frames will be made for both on and off-road use. If this affects the laws he must obey, please include that as well.

If you have any questions or concerns, please feel free to contact us here at the below listed numbers.

Thank you for your time and attention to this matter.