ID: aiam3740

Dear Mr. Scully: This is in reply to your letter of July 22, 1983, to Mr. Cavey of thi agency.; With respect to paragraph S4.1.1.7 of Standard No. 108 *Lamps Reflective Devices, and Associated Equipment* you have stated your understanding that that paragraph applies only to turn signal lamps manufactured between January 1, 1972 and September 1, 1973, and that turn signal lamps must now comply with SAE Standard J588e, September 1970.; Paragraph S4.1.1.7 did allow vehicular compliance with SAE J588d as a option to J588e. J588d required that any turn signal lamp used on a vehicle whose overall width was 80 inches or more have a minimum of 12 square inches effective projected luminous lens area. On the other hand, SAE J588e requires a minimum of 8 square inches effective projected luminous lens area on all single compartment rear turn signal lamps, regardless of vehicle width. However, on vehicles 80 inches or more in overall width, two turn signal lamps or compartments per side may be mounted closer together than 22 inches provided each meets single compartment photometric requirements and each has a minimum effective projected luminous lens area of 12 square inches. Thus, your understanding is correct.; I would also point out that, pursuant to Section S4.7.1 of Standard No 108, the continued manufacture of turn signal lamps meeting J588d is permissible as replacement equipment for vehicles manufactured between January 1, 1972 and September 1, 1978.; Mr. Cavey has provided the copy of BMCS regulations which is enclosed. Sincerely, Frank Berndt, Chief Counsel

ID: nht90-4.86

TYPE: Interpretation-NHTSA

DATE: December 14, 1990

FROM: John M. Marcum -- Chairman and CEO, Electric Vehicles, S.A.

TO: Administrator -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-1-91 from John Marcum to NHTSA Administrator; Also attached to letter dated 4-22-91 from Paul Jackson Rice to John Marcum (A37; VSA Sec. 108(2); Part 591)

TEXT:

Electric Vehicles, S.A. of 1776 I Street, N.W., Suite 850, Washington, D.C. 20006, is applying for a temporary exemption from the Federal Motor Vehicle Safety Standards for the EVSA prototype electric minibus. The firm is incorporated in Geneva, Switzer land and manufactures both electric minibuses and delivery trucks. EVSA has built its first two 16 passenger electric minibus prototypes (13,700 GVWR). They are currently being tested and evaluated in Allentown, Pennsylvania and Hong Kong. Through this testing program, EVSA plans to improve the performance and establish conformity to FMVSS requirements of our production vehicles. However, meeting all of these standards for our prototype would impair the development and field evaluation of this electri c vehicle. The 16 passenger minibus is powered with a Chloride 55 kw traction motor and carries 128 two volt batteries in four battery packs placed on top of the chassis and in sealed compartments under the passenger seats on either side of the the vehi cle. The batteries are accessible through fiberglass doors that run the length of the vehicle on either side. The minibus is a hybrid vehicle in that it is equipped with an optional 7 kw gasoline powered generator or range enhancer which is in a compar tment at the rear of the bus.

If this exemption is granted it will allow the vehicle to be used in a "free" test and evaluation passenger service operated in Allentown in the downtown shopping area. The bus will operate on a 1.7 mile loop that averages 20 stops per loop and where th e average speed is less than 10 mph. EVSA requests that this exemption be for a period of three months. During this time the minibus would be operated on the downtown loop by the Lehigh and Northhampton Transportation Authority (LANTA) as part of a join t test and evaluation program between EVSA, LANTA, the Pennsylvania Energy Office, Pennsylvania Power and Light Co. and others.

The prototype vehicle in Allentown differs in several respects from the FMVSS requirements. The first is that due to the use of thick "show type" fiberglass it is overweight. The vehicle unloaded is approximately 13,200 lbs. This means that when fully loaded to the 16 passenger (17 persons including the driver) capacity it will be about 2,000 lbs. or 15 percent over the GVWR of the chassis.

This vehicle also does not meet fully the requirement for emergency exits. It does not have a roof top emergency exit or the required one exit per three seating positions. However, it does have one side emergency door near the rear on the opposite side from the main entry door which does provide the total emergency exit requirement of 1139 square inches.

EVSA believes this should provide adequate egress in the event of an emergency in this limited operating mode.

The vehicle also fails to meet the standards in other areas including windshield washer, seat belt warning light and so on. These are in the process of being added to the vehicle during the test program. The chassis has passed its brake tests under ful l load at the Bendix proving ground and additional tests of the integrated vehicle are being carried out at the Mack Truck test track in Allentown.

The minibus has already demonstrated the capacity to carry 20 or more persons safely at its first showings in exhibitions in Athens, Greece and Houston, Texas. Moreover the front wheel drive heavy duty rail type chassis is conservatively rated and the m inibus will be driven at very low speeds on flat ground under passenger loads ranging from within the GVWR up to a maximum overload of 15 percent. Consequently, EVSA and its partners in the Allentown project do not believe there is any appreciable risk to the public resulting from the non-conforming aspects of this prototype vehicle. Operating this minibus in the downtown area during this experimental program would allow EVSA and LANTA to acquire valuable data for the designing and fabrication of futu re electric vehicles that would meet all of the applicable standards and would help fulfill the objective of the Alternative Fuels Vehicle Program of UMTA.

ID: nht90-2.32

TYPE: INTERPRETATION-NHTSA

DATE: April 25, 1990

FROM: Peter K. Brown -- President, KC HiLites, Inc.

TO: Chief Counsel -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7-2-90 to Peter Brown from Paul J. Rice; (A35; Std. 108) TEXT:

I am writing for your comments and approval regarding an Automotive Lighting product that our company intends to market.

The headlight systems on many late model vehicles operate differently than in the past. The low beams are extinguished when the high beam units are in use. This was done to reduce the foreground light of the low beams when the high beams are in use. I n actual use, having both systems operating in the high beam mode is superior.

With this in mind, I have studied paragraph 5.5.8 of the Federal Register Volume 54, No. 88 dated May 9, 1989. I interpret this to mean that headlights of a specific type, when used in a 4 headlight system, can all be illuminated at the same time on Hig h Beam.

The intended packaging, product and retail header card are enclosed for your inspection. I welcome any suggestions or comments that you may have. As these are prototype packages, will you please return them with your comments.

Our product catalog is enclosed to give you some idea of our company and products. Thanks for your help.

ID: aiam2106

Dear Mr. Masada: This responds to Takata Kojyo's October 1, 1975, questions whether Type 2 seat belt assembly with non-detachable shoulder belt (1) may be labeled in accordance with S4.1(k) of Standard No. 209, *Seat Belt Assemblies*, in only one location on either the upper torso or pelvic portion (A-I), (2) must be submitted (with the labeling modification) to a test laboratory or other facility as the basis for continued certification to the standard (A-II), (3) must be retested after a change is made to webbing length as the basis for continued certification to the standard (B-I), and (4), if testing is not required, must be submitted to a test laboratory or other facility as the basis for continued certification to the standard (B-II).; One label on either portion of a Type 2 seat belt assembly wit non-detachable shoulder belt may be used to satisfy the requirement of S4.1(k) of Standard No. 209.; The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 e seq.) requires manufacturers,(sic) to produce products covered by standards in compliance with those standards, as set by the National Highway Traffic Safety Administration (NHTSA), and to certify the products. It leaves the choice of testing methods up to the manufacturers. The NHTSA does not require retesting or submission to test laboratories as a basis for certification. A company like yours is free to choose any method that assures you that your products will conform if they are tested by the NHTSA as specified in the standard. This may take the form of tests, engineering calculations, or other means necessary to provide this assurance.; The answers given above pertain only to the Federal requirements fo seat belts. It may be necessary to contact other regulatory authorities as to the effect of these changes under their regulations.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam0990

Dear Mr. Kassab: This is in reply to your letter of December 27, 1972, concerning th absence from Motor Vehicle Safety Standard No. 208 of requirements for seat belts after the passive restraint requirements become effective.; Our aim in the last three years has been to improve the protectiv capabilities of the automobile so that it will automatically protect its occupants from serious injury and death. We do not intend in the least to disparage seat belts--to the contrary, we are making every effort to encourage their use. However, as passive restraints are installed, the marginal benefits to be gained from belts do not appear to be great enough to justify keeping them as required equipment.; The impacts that particularly concern you-- those occurring between 9 degrees and 270 degrees--are partially covered by the lateral impact test of Standard 208. Impacts in which the force is more nearly rearward are the subject of continuing investigation by our Research Institute, with a view toward possible improvements in the rear-end structure. If standards are proposed concerning rear impact protection, they will probably focus on improved seat structure or on rear-end modifications rather than on seat belts.; We think the course we are following will result in significantl increased protection for the motoring public.; Sincerely, Douglas W. Toms, Administrator

ID: nht71-1.27

DATE: 01/01/71 EST.

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Renault, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 4, 1971, to Mr. Clue Ferguson, requesting a clarification of certain sections of Federal Motor Vehicle Safety Standard No. 203 - Occupant Crash Protection, Docket 69-7, Notice 10.

It was our intent, under S4.5.3, to permit free substitution of Type 1 or Type 2 passive belts for seat belt assemblies required under S4. The standard specifies in S4.5.3 that a passive belt must conform to the requirements of S7.1 and to certain requirements of Standard No. 209, but it does not specify (Illegible Word) that shoulder belts should be detachable or that they should be non-detachable. The manufacturer may therefore choose either method of shoulder belt attachment. A detachable shoulder belt in a passive belt system must not, however, convert the system from passive to active status.

Please advise us if you need additional clarification of this point.

ID: aiam2800

Dear Mr. Friedlander: This responds to your February 23, 1978, letter asking whether th 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 passenge 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, Joseph J. Levin, Jr., Chief Counsel

ID: aiam0361

Dear Mr. Phelps: This letter is to further clarify an interpretation contained in ou letter of May 6, 1971, concerning the Tire Identification and Record Keeping Regulation.; We wish to make it clear that although the final-stage manufacturer ma designate someone to maintain the records required under section 574.10 of the Tire Identification and Record Keeping Regulation, the legal responsibility for maintaining the records remains with the final-stage manufacturer.; However, the incomplete vehicle manufacturer, or any intermediat manufacturer, may assume 'legal responsibility for all duties and liabilities imposed on manufacturers by (the Act) with respect to the vehicle as finally manufactured . . .' (49 C.F.R. 568.7). In such a case, the responsibilities for maintaining the records required by the Act and by the Tire Identification and Record Keeping Regulation will be assumed by the incomplete vehicle manufacturer, or any intermediate manufacturer, and the final-stage manufacturer will be relieved of all liability for maintaining the records.; We would also point out that the Tire Identification and Record Keepin Regulation was not meant to preclude the use of multiple designees for the maintenance of the required records. See the enclosed interpretation issued on May 28, 1971 (36 F.C. 9780).; Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: aiam0362

Dear Mr. Phelps: This letter is to further clarify an interpretation contained in ou letter of May 6, 1971, concerning the Tire Identification and Record Keeping Regulation.; We wish to make it clear that although the final-stage manufacturer ma designate someone to maintain the records required under section 574.10 of the Tire Identification and Record Keeping Regulation, the legal responsibility for maintaining the records remains with the final-stage manufacturer.; However, the incomplete vehicle manufacturer, or any intermediat vehicle manufacturer, may assume 'legal responsibility for all duties and liabilities imposed on manufacturers by (the Act) with respect to the vehicle as finally manufactured . . .' (49 C.F.R. 563.7). In such a case, the responsibilities for maintaining the records required by the Act and the Tire Identification and Record keeping Regulation will be assumed by the incomplete vehicle manufacturer, or any intermediate manufacturer, and the final- stage manufacturer will be relieved of all liability for maintaining the records.; We would also point out that the Tire Identification and Record Keepin Regulation was not meant to preclude the use of multiple designees for the maintenance of the required records. See the enclosed interpretation issued on May 28, 1971 (36 F.C. 9780).; Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: aiam3736

Dear Mr. Sims: This responds to your letter to Mr. Kratzke of my staff, concerning th emergency exit requirements of Safety Standard No. 217, *Bus window retention and release*, that apply to a 22 passenger bus with a gross vehicle weight rating in excess of 10,000 pounds. You indicated that your company counts the area provided by side doors in determining the total emergency exit openings for these buses. However, a state regulatory agency has advised you that side doors may not be used in computing the total emergency exit area required by S5.2 of Standard No. 217. Your letter stated that the state regulatory agency believes that the emergency exit opening for side exits must be provided by windows. The state regulatory agency is incorrectly interpreting the requirements of Standard No. 217 if they hold the position you have stated.; Section S5.2 of Standard No. 217 specifies requirements for th provision of emergency exits for buses, and S5.2.1 sets forth more specific requirements for buses with a gross vehicle weight rating of more than 10,000 pounds. As long as side doors meet all requirements applicable to emergency doors in Standard No. 217, they can be considered emergency exits for purposes of compliance with that standard. The agency has stated this position in several past interpretations, and has never indicated that only window emergency exits could be considered as side exits for purposes of compliance with section S5.2.1.; Should you have any further questions or need further information i this area, please contact Mr. Kratzke at this address, or by telephone at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel