NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
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ID: aiam1572OpenMr. Walter Case, 10426 Desdemona Drive, Dallas, TX 75228; Mr. Walter Case 10426 Desdemona Drive Dallas TX 75228; Dear Mr. Case: This responds to your June 13, 1974, request for approval of you 'park-lock' device under the parking brake system requirements of Standard No. 121 *Air brake systems*, 49 CFR S571.121. After a trailer's emergency air supply applies the brakes through the service brake chamber in response to a low service brake air supply, your device locks the brakes in the applied position.; The relevant provision of the standard states: >>>S5.6.3 *Application and holding*. The parking brakes shall b applied by an energy source that is not affected by loss of air pressure or brake fluid pressure in the service brake system. Once applied, the parking brakes shall be held in the applied position solely by mechanical means.<<<; The arrangement described would not meet this requirement because th energy source to apply the brakes (the emergency air supply) would be affected by loss of air pressure in the service brake system. For example, any failure in the service brake piston diaphragm would cause a loss of air pressure that would in turn 'affect' the energy source that applies the parking brake. The brake chamber housing assembly is an element which is not considered to be part of the service brake system for this requirement.; Standard No. 121 does not specify the design of brake syste components. Therefore we neither approve nor disapprove the use of particular components like the 'park-lock' device. It may be used in any parking brake system which meets the requirements of the standard.; I would like to point out that the standard becomes effective Januar 1, 1975, for trailers, and that it does not regulate air brake systems on trailers manufactured before that date.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam4320OpenMr. Robert A. Rogers, Director, Automotive Safety Engineering, General Motors Corporation, General Motors Technical Center, 30400 Mound Road, Warren, MI 48090-9015; Mr. Robert A. Rogers Director Automotive Safety Engineering General Motors Corporation General Motors Technical Center 30400 Mound Road Warren MI 48090-9015; Dear Mr. Rogers: This responds to your letter to Mr. Barry Felrice, our Associat Administrator for Rulemaking, in which you explained why General Motors (GM) believes that it is not subject to the reporting requirements set forth in 49 CFR Part 544, *Insurer Reporting Requirements*. We conclude that GM is an 'insurer' as that term is defined in section 612(a)(3) of the Motor Vehicle Information and Cost Savings Act 15 U.S.C. 2032(a)(3) , that GM is therefore subject to the requirements of Part 544, and that GM is overdue in filing its report for the 1985 calendar year.; 49 CFR S544.3 specifies that, 'This part applies to the issuers o motor vehicle insurance policies listed in Appendices A or B, and *to any person which has a fleet of 20 or more motor vehicles (other than a governmental entity) which are used primarily for rental or lease and are not covered by theft insurance policies issued by insurers of motor vehicles,*' (Emphasis added). The emphasized language in the regulation is simply a quotation of the language used in section 612(a)(3) of the Cost Savings Act. Because the regulation uses the same language as the statute to describe this type of insurer, Part 544 applies only to those insurers that are statutorily-required to file these reports.; You noted in your letter that, 'GM has an employee lease fleet of 400 cars on which it does not have theft insurance.' As such, GM is an insurer within the meaning of section 612(a)(3), because it:; >>>1. Has a fleet of 20 or more vehicles, 2. Uses the vehicles primarily for rental or lease, and 3. Does not have theft insurance policies for this fleet.<<< GM appeared to agree that it was an insurer within the meaning of th statute when it filed its July 29, 1986 comments to the proposed Part 544. On page 2 of its comments, GM stated that the proposed criterion of exempting only those fleets with fewer than 20 vehicles would result in voluminous additional individual reports which would account for a relatively small percentage of the total vehicle population. GM stated that its lease fleet represents less than 5000 of one percent of all U.S. passenger cars. On page 3 of those comments, GM stated: ' The proposal requests additional information to aid in the agency's efforts to establish an appropriate exemption for small rental and leasing companies. As stated above, GM's lease program is expected to have no more than 5000 participants in 1987.' GM then stated that no data on costs or thefts were available for its leased fleet. This comment certainly implies that GM believed it would be required to report if the proposed requirements were adopted. Since the proposed requirements were adopted in this area, NHTSA thought that the vehicle manufacturers clearly understood that they were subject to these requirements, if they had a fleet of vehicles that were rented or leased to employees.; However, in your recent letter, you stated that you now believe tha you were not required to report theft data for this fleet for three reasons. First you stated that the GM 'evaluation fleet', which consists of 41,000 vehicles is *not* used primarily for rental or lease. According to your letter, slightly more than 4,000 vehicles are leased to employees. Since only 4,000 out of 41,000 vehicles in this fleet are leased to employees, you concluded that the 41,000 vehicle fleet is not used primarily for rental or lease. Hence, you believe that the statute does not require GM to report theft data for the 41,000 vehicle fleet. NHTSA agrees that GM is not required to file a report for the 41,000 vehicle fleet. The law requires GM to report *only* for the 4,000 vehicle fleet that is leased to employees.; Second, you argued that GM's 'evaluation lease' establishes conditional contract that limits the rights of the employee lessees. You sated that, 'Conventionally, the term 'lease' is applied to hiring on a lease with full rights of use for the lessee.' Since GM's evaluation lease limits the rights of the lessee, you stated that it is not a 'lease' within the conventional meaning of that word, so GM is not required to report by the statute. NHTSA agrees that the term 'lease' was used in its conventional sense in section 612. However, neither standard dictionaries of the English language nor Black's Law Dictionary define a lease as a transaction that gives *unconditional* rights of use to the lessee. Instead, a lease is generally defined as a transaction whereby an owner gives another the use of his property for a period of time in return for some compensation. GM's employee lease program satisfies this test, so GM is required to report theft data on the vehicles in its employee lease fleet.; Third, GM noted that the preamble to the final rule establishing Par 544 referred to this type of insurer as 'rental and leasing companies.' Since GM is not a rental *and* leasing company, it concludes that Part 544 was not intended to apply to it. NHTSA agrees that GM is not a rental and leasing company. That term was used as a shorthand notation for the following language in the application section of Part 544 and in the statute: 'any person which has a fleet of 20 or more motor vehicles (other than a governmental entity) which are used primarily for rental or lease and are not covered by theft insurance policies ...' This shorthand notation was not intended in any way to limit the requirement in Part 544 and the statute for such persons to file reports. Moreover, the language of Part 544 and the statute prevail over the language in a preamble in any event. Accordingly, GM is required to comply with its statutory duty to file reports.; GM has not yet filed its report for the 1985 calendar year, which wa due by January 31, 1987. Since the report was not filed because of a misunderstanding as to whether GM was subject to the requirements of Part 544, NHTSA will not take any enforcement action against GM for this failure to file a timely report if we receive your report under Part 544 for the 1985 calendar year within 45 days of the date of this letter.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2623OpenMr. John B. Rehm, Busby and Rehm, Counsellors at Law, 900 17th Street, N.W., Suite 714, Washington, DC 20006; Mr. John B. Rehm Busby and Rehm Counsellors at Law 900 17th Street N.W. Suite 714 Washington DC 20006; Dear Mr. Rehm: This responds to your letter of June 21, 1977, requesting our office t advise the U.S. Customs Service that a new 'camper' vehicle manufactured by Subaru would be classified as a multipurpose passenger vehicle by the National Highway Traffic Safety Administration (NHTSA) in contradiction of a previous letter from the NHTSA to Customs.; As noted by Mr. Armstrong of this agency in his letter of January 17 1977, to the Customs Service, the NHTSA does not assign or approve in advance a classification for a particular vehicle design. Any ultimate agency determination as to vehicle classification would generally arise only in the context of compliance or enforcement proceedings. The NHTSA does issue advance opinions concerning vehicle classification when requested to do so by vehicle manufacturers. These opinions are necessarily qualified, however, by statements that the opinion is based solely on the description of the vehicle as supplied by the person making the request. Our opinion as to classification is, of course, dependent on the manner in which the vehicle is described.; As defined in 49 CFR 571.3, a 'truck' is a motor vehicle designe primarily for the transportation of property or special purpose equipment. A 'multipurpose passenger vehicle' is defined in Section 571.3 as a vehicle designed to carry 10 persons or less which is contructed (sic) either on a truck chassis or with special features for occasional off-road operation. The Subaru 'camper' is constructed on a truck chassis and has special features for off-road use (4-wheel drive), which would qualify it as a multipurpose passenger vehicle. Therefore, the determinative question is whether the Subaru vehicle is designed primarily for carrying property, in which case it would be classified a truck.; In spite of Subaru vehicle's resemblance to a pick-up truck o Ranchero, there is a basic distinction in design. In the case of a pick-up or Ranchero truck there is a separate vehicle area that is clearly designed for cargo-carrying alone. In the case of the Subaru vehicle, however, the manufacturer has placed seats for two people in that area that would ordinarily be used for carrying property. Since the manufacturer has chosen to use that area for the purpose of carrying passengers, it cannot be said that the vehicle is designed *primarily* for carrying property.; Based on this rationale, the NHTSA concludes that the Subaru 'camper qualifies as a 'multipurpose passenger vehicle,' and that the preliminary opinion of the Office of Standards Enforcement was inaccurate. I would point out, however, that the Federal motor vehicle safety standards applicable to multipurpose passenger vehicles are equally as stringent as the standard applicable to trucks, if not more so.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2273OpenMr. L. W. Smith, President, Transportation Design & Technology, Inc., P.O. Box 28052, San Diego, CA 92128; Mr. L. W. Smith President Transportation Design & Technology Inc. P.O. Box 28052 San Diego CA 92128; Dear Mr. Smith: This responds to your November 14, 1975, request to know how th tensile strength at a joint is determined under S6.2 of Standard No. 221, *School Bus Body Joint Strength*, in the case of more than two body components joined by the same fastener.; An extensive discussion of joint strength requirements and tes procedures was recently sent to Blue Bird Body Company. Your question is addressed in that discussion and a copy is enclosed for your information.; Yours truly, Stephen Wood, Assistant Chief Counsel |
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ID: aiam2789OpenMr. Eduardo A. Santiago, 1137 Barium Road, Modesto, CA 95351; Mr. Eduardo A. Santiago 1137 Barium Road Modesto CA 95351; Dear Mr. Santiago: This responds to Raycor Industries' March 13, 1978, question whethe Standard No. 121, *Air Brake Systems*. applies to an air dryer that is installed in the air brake system of trucks that must comply with the standard.; The answer to your question is no. Paragraph S3 (Applicability) o Standard No. 121 states that the standard applies to trucks, buses, and trailers equipped with air brake systems (with some specified exceptions). The standard therefore applies only to vehicles, and does not apply to motor vehicle equipment such as the Raycor air dryer unit. The vehicles in question must, of course, conform to Standard No. 121 following installation of the device, if the installation occurs prior to the first purchase in good faith for purposes other than resale.; A copy of Standard No. 121 is enclosed for your information. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3032OpenMr. James Tydings, Thomas Built Buses, Inc., 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. James Tydings Thomas Built Buses Inc. 1408 Courtesy Road P.O. Box 2450 High Point NC 27261; Dear Mr. Tydings: This responds to your May 21, 1979, letter confirming your discussion with Roger Tilton of my staff relating to the emergency exit requirements of school buses that are constructed with an additional exit door. The additional door is installed so that the vehicle can be better used as a general transit vehicle when not in use for school purposes.; The statements that you make in your letter are, for the most part accurate. However, your third statement which indicates that the additional door could not be marked as an emergency exit is not entirely accurate. Additional emergency exits in school buses, beyond those required by Standard No. 217, *Bus Window Retention and Release*, must comply with the emergency exit requirements applicable to exits in non-school buses. If the door to which you refer is not designed or constructed as an emergency exit but rather is designed as an additional door for the routine loading and unloading of passengers, it need not be labeled as an emergency exit. If on the other hand the door is intended as an emergency exit and is constructed in accordance with the emergency exit requirements for doors in non-school buses, it should be labeled as an emergency exit in accordance with the labeling requirements for exits in non-school buses.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3462OpenMr. J. Kawano, General Manager, U.S. Representative Office, Toyota Motor Co., Ltd., One Harmon Plaza, Secaucus, NJ 07094; Mr. J. Kawano General Manager U.S. Representative Office Toyota Motor Co. Ltd. One Harmon Plaza Secaucus NJ 07094; This responds to your letter of February 3, 1981, asking two question about Safety Standard No. 105, *Hydraulic Brake Systems*. The questions were asked in regard to a type of brake reservoir you are considering producing which would service both the braking system and the clutch.; The first question is whether an interpretation you have made o section S5.4.2 of the standard is correct. The essential issue to that question is whether hydraulic fluid which is available to the clutch, either for normal use or in the event of clutch failure, can be counted as part of the minimum capacity required by section S5.4.2 for the braking system. The agency interprets the standard to require that the minimum fluid capacity requirements for brake reservoirs be met by fluid which is not available to the clutch, either during normal use or in the event of clutch failure. Thus, as will be explained below, your interpretation is incorrect.; Safety Standard No. 105 establishes requirements for a vehicle' braking system, including minimum capacity requirements for the reservoirs. Neither this standard nor any other Federal motor vehicle safety standard includes requirements for the reservoirs of a vehicle's clutch. While nothing prohibits a manufacturer from producing a master cylinder which service both the vehicles braking system and clutch, the minimum fluid capacity requirements for reservoirs must be met separately for a vehicle's braking system.; The first sentence of section S5.4.2 states: >>>Reservoirs, whether for master cylinders or other type systems shall have a total minimum capacity equivalent to the fluid displacement resulting when all the wheel cylinders or caliper pistons serviced by the reservoirs move from a new lining, fully retracted position (as adjusted initially to the manufacturer's recommended setting) to a fully worn, fully applied position, as determined in accordance with S7.18(c) of this standard.<<<; This section specifies the total minimum fluid capacity that vehicle's braking system reservoirs must have. That amount is determined by reference to the vehicle's braking system, i.e., by the fluid displacement which results when all the wheel cylinders or caliper pistons serviced by the reservoirs move from a new lining, fully retracted position to a fully worn, fully applied position. The purpose of this requirement is to assure that a vehicle's braking system reservoirs have adequate fluid capacity to service the brakes.; The agency interprets section S5.4.2 to require that the minimum flui capacity requirements for brake reservoirs be met by fluid which is solely available to the brakes. If fluid is available to both the brakes and the clutch, some of that fluid is available to both the brakes and the clutch, some of that fluid will be used by the clutch in normal service and thus be unavailable to the brakes. In the event of clutch failure, all of the common fluid may be used by the clutch. Therefore, while Standard No. 105 does not prohibit manufacturers from producing master cylinder with reservoirs that have some fluid available to both the braking system and clutch, non of that common fluid may be counted toward meeting the minimum fluid capacity requirements of section S5.4.2.; Your interpretation of section S5.4.2 is incorrect because it count common fluid toward meeting these requirements. In reference to Figure 1 that you attached with your letter, no fluid above the top of the wall dividing X and Y from Z should be counted toward meeting section S5.4.2's requirements.; We are aware that this interpretation conflicts with our July 10, 1974 interpretation that you attached with your letter and regret any inconvenience. That interpretation indicated that all five designs included in your letter of May 24, 1974, appeared to conform to section S5.4.1, providing that the reservoir capacity requirements of section S5.4.2 were met. That interpretation did not properly consider the requirements of section S5.4.2, as discussed above. It should have indicated that designs (3) and (4) do not comply with Standard No. 105 because they cannot meet section S5.4.2's minimum capacity requirements without counting fluid that is common to the braking system and clutch.; Your letter also asked about which fluid should be counted i determining the minimum warning level specified in section S5.3.1(b). That section refers to a drop in the level of brake fluid in any master cylinder reservoir compartment to less that the recommended safe level specified by the manufacturer or to one-fourth of the fluid capacity of that reservoir compartment, whichever is greater.; The minimum warning level is thus determined by the fluid capacity o each compartment rather than by the total capacity of the reservoir, unless the manufacturer recommends a higher safe level. In reference to Figure 1 that you attached with your letter, the compartments in question are X and Y. Thus, the warning level for compartment X must not be less than 1/4 of the capacity of X. Similarly, the warning level for compartment Y must not be less that 1/4 the capacity of Y. Since there may be safety advantages to higher warning levels, particularly where the capacity of individual compartments is small in relation to the capacity of the reservoir, you may wish to specify a higher warning level such as that indicated in Figure 1, i.e., at a level above the wall separating X form Y.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3198OpenMr. Jack D. Rainbolt, Chief Engineer, Air Brakes Transportation Division, BF Goodrich Company, P.O. Box 340, Troy, OH 45373; Mr. Jack D. Rainbolt Chief Engineer Air Brakes Transportation Division BF Goodrich Company P.O. Box 340 Troy OH 45373; Dear Mr. Rainbolt: This responds to your October 29, 1979, letter asking about brak adjustments prior to testing for compliance with Standard No. 121, *Air Brake Systems*. In your letter, you ask that the agency permit up to three adjustments during the burnish for dynamometer testing.; By letter of interpretation and by preamble to our November 197 Federal Register Notice (39 FR 39880), adjustments were permitted during the burnish procedures in S6.1.8 and S6.2.6 for the purpose of controlling brake temperature. According to agency information at the time of those interpretations, controlling brake temperature was the only reason that would require the use of brake adjustments during burnish. In a subsequent letter to the agency, you requested that we modify that position in light of your experience with disc brakes and their need for adjustment during burnish for dynamometer testing for reasons other than temperature control. The agency denied that request in April of 1979 while suggesting that the NHTSA would reconsider if more supporting data were supplied.; In response to the agency's request for more data, you have submitte another request for interpretation. To support this request, you have provided information in you letter and have also provided other information directly to our technical staff. As a result of this information, the agency agrees that adjustments during the burnish procedures may be necessary for reasons other than temperature control. Accordingly, the agency will permit adjustments during the burnish procedures for the sections cited above for any reason.; The standard presently is silent on the issue of how many brak adjustments may be made during burnish. As discussed with you and your staff we are considering limiting the number of adjustments to three during the burnish tests. However, no limitation is in effect at this time. The agency will undertake rulemaking shortly to limit the number of adjustments during burnish and encourages manufacturers to limit adjustments to three in the interim.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4348OpenMarzia Puccioni Jones, Alpex Manufacturing Company, 10926 'J' Street, Omaha, NE 68137; Marzia Puccioni Jones Alpex Manufacturing Company 10926 'J' Street Omaha NE 68137; Dear Mr. Jones: This letter responds to your letter enclosing a prototype horn/ligh and requesting information on its 'legality.' The horn/light is intended to be installed on the roof of a pickup truck or van. The light is located on the rear of the horn and would be visible to following drivers. The light comes on when the driver presses the horn button to sound the horn and goes off when the horn button is released. I regret the delay in this reply.; You asked whether the horn complies with safety and other pertinen regulations, whether the light at the back of the horn must be red or amber, whether it is permissible to mount the horn on the cab of a pick-up truck or van roof, and whether the horn is 'DOT-approved,' or if it would be in violation.; The National Highway Traffic Safety Administration (NHTSA) issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment pursuant to its authority under the National Traffic and Motor Vehicle Safety Act. However, NHTSA does not approve motor vehicles or motor vehicle equipment, nor does it endorse any commercial product. Instead, the Vehicle Safety Act establishes a 'self- certification' process under which each manufacturer must certify that its product meets applicable safety standards. Periodically, NHTSA tests whether vehicles or equipment comply with these standards, and may investigate alleged safety-related product defects.; There is only one standard which may apply to your product if it i installed on new vehicles. Standard 108, *Lamps, Reflective Devices, and Associated Equipment*, applies to vehicle lighting. As we understand your product, its light is not intended to serve as any of the lights required by the standard on a van or pickup. Therefore, the requirements directed to those types of lights would not be applicable. However, there is a general requirement that might affect your horn/light. S4.1.3 prohibits the installation of any light that would impair the effectiveness of any required light. The activation of the light on your product could lead following drivers to believe incorrectly that the vehicle equipped with your product is stopping. Repeated false stopping signals might reduce the following driver's responsiveness to the activation of the vehicle's brake lights.; If your product is installed as aftermarket equipment, it would not b subject to any requirement in Standard No. 108. Standard No. 108 covers aftermarket lighting equipment only to the extent that the aftermarket light replaces required original lighting equipment. Because there is no original equipment requirement for the kind of light you described, the standard does not apply to your aftermarket product.; Regardless of whether your product is affected by any of our standards please be aware that if you or the agency finds your product to contain a safety-related defect after you market the product, you are responsible for conducting a notice and recall campaign under S154 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C 1414).; Further, you should be aware that State law may apply to products suc as your horn/light. You may wish to consult the State and local transportation authorities in the areas where you intend to market your horn.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3177OpenMr. Frank Dana, Haynsworth, P.O. Box 2048, Greenville, SC 29602; Mr. Frank Dana Haynsworth P.O. Box 2048 Greenville SC 29602; Dear Mr. Dana: This is in response to your telephone conversation with Kathy DeMete of my staff on Friday, December 21, 1979. You asked for the status of section 580.5(a)(1) of Title 49 of the Code of Federal Regulations. That section exempts from the odometer disclosure requirements anyone transferring a vehicle having a gross vehicle weight rating of more than 16,000 pounds. That exemption is part of the regulation, originally issued in January 1973, which prescribes rules requiring a transferor of a motor vehicle to make a written disclosure to the transferee concerning the odometer reading and its accuracy.; In January 1977, the exemption was declared void by the United State District Court for the District of Nebraska on the grounds that the National Highway Traffic Safety Administration (NHTSA) has exceeded its authority in fashioning the exemption. Notwithstanding the court's decision, the NHTSA believes that it has the authority to create exemptions for vehicles for which the odometer reading is not relevant. The exemption, consequently, remains a part of the odometer disclosure regulations.; For your information, I have enclosed copies of the statement submitted by Freightliner, White, and the National Association of Motor Bus Operators, which support the exemption for larger vehicles.; Sincerely, Frank Berndt, Chief Counsel |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.