ID: nht69-1.16

DATE: 05/21/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Amorada Glass Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 25, 1969, forwarded to me by the Federal Trade Commission.

A windshield classified as a second by the manufacturer must nevertheless meet the requirements of Motor Vehicle Safety Standard No. 205 (Glazing materials).

If you have any information indicating that windshields marked seconds do not comply with the standard I would appreciate your sending me such information with the names of the manufacturers and dealers selling the windshields so that the Bureau can further investigate the matter.

Sincerely,

National Highway Safety Bureau, Federal Highway Administration, Department of Transportation,

Attention: Robert Brenner,

Acting Administrator.

Gentlemen:

The enclosed copy of a letter, dated April 22, 1969, from Mr. Richard R. Miller, President, Amerada Glass Company, Elk Grove Village, Illinois, referring to the installation of unsafe windshield glass is forwarded for appropriate consideration by your Bureau under applicable motor vehicle safety standards.

Mr. Miller has been advised of this referral.

With best wishes, I am

Sincerely yours,

Hugh B. Helm --

Chief, Division of Advisory Opinions,

Bureau of Industry Guidance,

Federal Trade Commission

Enclosure

April 22, 1969

Federal Trade Commission

Gentlemen:

Having received a copy of Steven John Fellman's letter of April 7, 1969, directed to your offices, regarding the installation of "seconds" windshields by members of the National Glass Dealers Association, I wish to advise the availability of further information on this matter for your immediate consideration.

"B" line insurance firms in many parts of the country are well aware of the availability of "seconds" and prepare their purchase orders accordingly. It is a known industry fact that the three largest independent manufacturers of curved windshields allow sales of "seconds" windshields only to their largest and preferred customers, those giving them the major share of the replacement business in their area.

This practice definitely discriminates against the small, legitimate buyer unable to buy the lower cost "second" from the independent manufacturer, distributing only through his selected distributor.

I feel very strongly that the Department of Transportation should be advised that the installation of rejects deceives the public, and provides unsafe windshields due to distortion, double vision and imperfections in the glass which would normally be considered rejects and destroyed by those original equipment windshield manufacturers who do not sell windshields considered to be unsuitable for original equipment or replacement installation sales.

A thorough review of practices indicated above should be made without delay. Your reply will be awaited with genuine interest.

Very truly yours,

AMERADA GLASS COMPANY --

Richard R. Miller, President

ID: nht70-2.38

DATE: 12/08/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 26, 1970, submitting a petition for reconsideration concerning Motor Vehicle Safety Standard No. 215, "Child Seating Systems", published September 23, 1970 (35 F.R. 14478). Because of the timing of your petition, it has been treated as a petition for rulemaking pursuant to 49 CFR @@ 553.35, 553.31. Your letter requests that two amendments be made to the standard before its effective date of April 1, 1971. First, you request that paragraph S4.3 be amended to substitute the language proposed for that paragraph in the notice of proposed rulemaking concerning Standard No. 213, also published on September 23, 1970 (35 F.R. 14786). Second, you request that the standard be amended to provide an alternative test procedure that is specified in your petition, as you believe "the test procedure under S4.11.1 and S5 of the standard to be wholly inappropriate for the Ford child restraint system."

With reference to your request concerning paragraph S4.3 of the standard, the Bureau did not intend the standard to require all child seating systems to have adjustable components to directly restrain the child. Consequently, the Bureau will not consider that a child seating system without adjustable components to directly restrain the child fails to comply, for that reason, with paragraph S4.3 of the standard. The language of the notice of proposed rulemaking, insofar as it states, "Each child seating system component that is adjustable and is designed to restrain the child directly . . ." is a clarification of the present language. For the proposed amendment to be made effective before April 1, 1971, is therefore unnecessary.

Regarding your request for an alternative test procedure, you state in your letter that "using the test procedures in S5.1, the torso block applies an unstabilized, concentrated load on the Tot-Guard shield much like that which would be applied by one cylinder loading another with their axes at 90 degrees to each other." It is not mandatory under S5.1(d) that the load be applied to the torso block at a single point. It may be applied at two or more points as long as the intersection of the load application line and the back surface of the torso block is not more than 8 inches or less than 6 inches above the bottom surface of the torso block. In the case of an unstabilized loading condition, such as that which you state occurs with the Tot-Guard, the load could be applied through a fixture attached to both the top and bottom of the torso block as long as the load application line is within the limits specified. During the test, however, only the torso block and not the attachment fixture may contact the seating system.

For the reasons specified above, the amendments you have requested have been found unnecessary and unjustified, and your petition is accordingly denied.

ID: nht70-2.6

DATE: 04/30/70

FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA

TO: Tradewind Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 15, 1970, concerning the location requirements for lamps and reflectors as specified in Federal Motor Vehicle Safety Standard No. 108.

In answer to your first question, intermediate side marker lamps and intermediate side reflex reflectors are not required on trucks that are 60 inches or more in overall width and less than 30 feet in overall length.

In answer to your second question, front clearance lamps are not required on the truck body, provided the clearance lamps on the truck cab indicate the left and right extreme edges of the vehicle. For the vehicle shown on your drawing no. 130003A, it would appear that clearance lamps must be mounted on the truck body to provide an indication of the extreme edges of the vehicle. With clearance lamps on the body, duplicate lamps would not be required on the cab.

In answer to your third question, Table II of Standard No. 108 specifies that intermediate side marker lamps and reflectors be located at or near the midpoint between the forward and(Illegible Word) side marker lamps or reflectors, respectively. For side marker lamps the mounting height above the road surface is "not less than 15 inches." For side reflex reflectors the mounting height is "not less than 15 inches nor more than 60 inches." With this flexibility in mounting requirements, we are not aware of any truck body designs that would require installation of these devices "on the upper edges of the sides" of the truck bodies. Again, intermediate side marker lamps and reflectors are not required on vehicles that are less than 30 feet in overall length.

Removable sides (stakes) of farm and commercial stake-type bodies are not considered to be a permanent part of the vehicle.

Therefore, lamps and reflectors mounted on the platform bed of the body will meet the location requirements of Standard No. 108.

The alternative locations of lamps and reflectors on farm grain trucks and dump trucks, as suggested by your Drawing No. 130003A, are in conformance with Standard No. 108, except for location of front and rear clearance lamps. If such vehicles have permanent sides, the clearance lamps should be mounted "as near as practicable to the upper left and right extreme edges of the vehicle." The wording "as near as practicable" was purposely chosen to provide the vehicle manufacturer with a degree of flexibility in mounting clearance lamps on special purpose vehicles to insure that these lights will not be obscured or otherwise rendered ineffective in operation. Since certain vehicles may be covered with tarpaulins, this requirement may be met by mounting the clearance lamps as high as practicable and yet allow space for the use of tarpaulins,

Your concern for assuring compliance with the requirements of Standard No. 108 is greatly appreciated.

ID: nht72-3.47

DATE: 10/13/72

FROM: CHARLES H. HARTMAN FOR DOUGLAS W. TOMS -- NHTSA

TO: Mr. Jesse R. Hollins

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your petition of August 15, 1972, as supplemented by your brother's letter of August 28, 1972, requesting our consideration of your seat belt warning system as a substitute for the warning and interlock systems currently specified in Motor Vehicle Safety Standard No. 208.

As we understand the operation of your system, one of its operating modes resembles the mode presently specified in S7.3.1 of the standard. Your system provides for the operation of a warning signal when the ignition is "on" and the seat belts at occupied front positions have not been operated. Section S7.3.1, considered by itself, would permit such a system, even though that section does not require the warning to operate unless the engine is operating and the vehicle is in a forward gear.

However, your system does not meet the requirement of S7.3.3 that the warning not operate when the vehicle is idling with the transmission in park or neutral position and the belts have not been operated. The argument presented in your brother's letter is that the sudden operation of the warning system when the transmission is placed in a forward gear would be an annoyance to occupants and would result in circumvention of the system.

The NHTSA position is that the convenience of being able to sit unbuckled in a parked car without the warning is such that this "quiet" period should continue to be required. It may be that some occupants will be bothered when the warning begins to sound as they place the car in gear. However, we are persuaded that the current system would be less likely to be circumvented than a system that has no period of non-operation.

The other operating mode of your system has no direct counterpart in Standard 208. As you describe it, returning the ignition to the "off" position will activate the warning system, even after removal of the key, until the belts are returned to their stowed positions. Our letter of August 17, 1972, explained that this will not conform to the requirement of S7.3.2 that the warning must not operate when the belts at occupied front positions have been operated.

We recognize that there are other possible alternative to the required interlock system as a means of encouraging seat belt usage, and several have been suggested. We consider it important, however, that these systems work in a substantially uniform manner, for maximum public safety, acceptance and convenience. On the basis of all the material we have received to date, including yours, we have decided that our present requirements represent the best combination for the alternative to passive restraints in the period 1973-1975. I therefore must deny your petition to substitute your system, or allow it as an alternative, for the interlock system.

ID: nht72-4.16

DATE: 10/27/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 18, 1972, on the subject of warning system and interlock system operation under Standard No. 208.

The table enclosed with your letter lists all combinations of front seat occupancy and front seat belt usage that are possible in a vehicle with two front seating positions. You ask, as to each of these combinations, whether you have correctly understood the operation of the interlock and warning system. We find that a large majority of the combinations shown in your table are correctly interpreted but that a few are in error or are in need of further clarification.

The primary source of error in the table seems to be confusion as to the effect of the driver's absence from his seat. Under S7.4.1, the conditions under which a failure to operate the belt will require the interlock system to prevent engine operation are specified in S7.4.1(a) and (b). Each of these conditions specifies that the driver's position is occupied, so that if the driver is not in his seat neither condition (a) nor condition (b) is met and interlock system operation is not required.

Applying this interpretation to the matrix in your table discloses that two cases, 18 and 25, are incorrectly interpreted. In each of these cases the driver is not in his seat and the interlock would not be required to operate, even though in both cases the passenger has operated his belt out of sequence and in one case the belt at the vacant driver's position is buckled.

Although interlock operation is not required in cases 18 and 25, a manufacturer would be permitted to design his interlock system to operate in these circumstances. Eighteen and 25 should therefore be treated in the same manner as the other cases in the matrix (11-17, 24) in which interlock operation is shown to be within the manufacturer's discretion.

The warning system, which is required to operate when the ignition is in the start position if the operations required by S7.4.1 to start the engine have not been performed, is on a different footing under conditions where the interlock is permitted, but not required, to operate. Under such conditions, S7.3.5.4 does not require the warning to operate in the start position. We would, however, strongly recommend that the warning system be designed to operate whenever the interlock prevents engine operation, regardless of whether or not S7.4.1 requires operation.

One other case in your table should also be corrected. Under Case 4, you indicate that interlock operation would be within the discretion of the manufacturer. It is our opinion that if the driver has properly operated his belt the interlock and warning system should not operate, even though the belt at the empty passenger's seat has been fastened.

Please advise us if you have further questions.

ID: nht92-3.1

DATE: October 28, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Spencer A. Darby -- Vice President, Engineering, Sate-lite Manufacturing Co.

TITLE: None

ATTACHMT: Attached to letter dated 8/17/92 from Spencer A. Darby to Legal Counsel - FMVSS 125, NHTSA (OCC-7675)

TEXT:

This responds to your inquiry about whether a warning device would comply with Federal Motor Vehicle Safety Standard No. 125, Warning devices (49 CFR S571.125). You were specifically concerned about the implications of adding a battery operated flashing light to a warning device that otherwise complies with the Standard. You stated that placing flashing lights between the reflex reflectors would enhance the device's conspicuity at night. I am pleased to have this opportunity to explain our require- ments to you.

By way of background information, the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the "Safety Act") gives the National Highway Traffic Safety Administration (NHTSA) the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. We have exercised this authority to establish Standard No. 125. The Safety Act provides that no person shall "manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States" any new motor vehicle or new item of motor vehicle equipment unless the vehicle or item of equipment complies with the applicable standard. (See 15 U.S.C. 1397(a)(1)(A).) NHTSA has no authority under the Safety Act to approve, certify, or otherwise endorse any commercial product. Instead, the Safety Act establishes a self-certification process under which each manufacturer is required to certify that each of its products meets all applicable Federal Motor Vehicle Safety Standard. (See 15 U.S.C. 1403.) I am enclosing a general information sheet explaining NHTSA's regulations.

As your letter states, Standard No. 125 applies to "devices, without self- contained energy sources that are designed to be carried in motor vehicles and to warn approaching traffic of the presence of a stopped vehicle, except for devices designed to be permanently affixed to the vehicle." (emphasis added; see section S3) In other words, Standard No. 125 does not apply to warning devices with self-contained energy sources. In previous interpretations, the agency has determined that the phrase "self-contained energy sources" includes such things as battery powered lights. Accordingly, a warning device to which a battery operated flashing light was added would not be subject to Standard No. 125.

You also asked whether a vehicle required to have three "125 warning triangles" would be required to have three non-lighted complying triangles set out as well. Please be aware that NHTSA does not regulate the use of warning devices. I am forwarding your letter to the Federal Highway Administration (FHWA) which is authorized to regulate some motor vehicle

operators and vehicle operations.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: nht95-7.40

TYPE: INTERPRETATION-NHTSA

DATE: November 17, 1995

FROM: Samuel J. Dubbin -- Chief Counsel, NHTSA

TO: Jim Young -- Wheeled Coach

TITLE: NONE

ATTACHMT: ATTACHED TO 10/17/95 LETTER FROM Jim Young to John Womack (OCC 11303)

TEXT: Dear Mr. Young:

This is in reply to your FAX of October 17, 1995, asking for interpretations of Motor Vehicle Safety Standard No. 108, as in relates to "customer specifications for options incorporated into, or in addition to FMVSS lighting." You have described these options as:

"Brake override circuit for rear facing warning lights. The rear warning lights flash as warning lights until the brakes are applied, at which time they become stead burn. This option is in addition to the standard brake lights. If this is acceptable, should the lights be required to meet all requirements of stop lights? (ie.; maximum luminous intensity, color, etc. . .)"

As you clarified in a phone conversation with Taylor Vinson of this Office on November 2, the "rear facing warning lights" are part of the ambulance lighting system which is not a system required by Standard No. 108. This option is permissible. Although there is no Federal legal requirement that governs the performance of ambulance warning systems, we recommend that the rear facing warning lights are red, the required color for stop lamps, inasmuch as the intent seems to be provide an additional indication that the brake have been applied.

"Brake Enhancer. Standard or additional stop lights are made to flash on/off several times before going steady burn."

This is not permissible. Standard No. 108 requires all stop lamps to be steady burning.

"Back-up alert strobes. Rear facing high intensity strobe lights that are activated when the gearshift lever is placed into reverse gear."

Optional equipment is permissible if it does not impair the effectiveness of lighting equipment required by the standard. You have not indicated the color of the strobe lamps. If they are red or amber, they could cause confusion in the eyes of an observer when operated simultaneously with the steady burning

P2

white backup lamp. There is a lesser possibility of confusion if they cast a white light, as long as they do not mask the steady burning backup lamp. In that event, the strobes could be fitted to the ambulances.

"Taillight flashers. Taillights or brake lights are flashed alternate to backup lights until brakes are applied, at which time they go steady burn. The option at times may be requested to only work of the rear doors on the ambulance are open."

This is not permissible. Standard No. 108 requires taillamps as well as stop lamps to be steady burning, under all circumstances.

If you have further questions, you may refer them to Taylor Vinson (202-366-5263).

Sincerely,

ID: 11856-2.PJA

Mr. R. Karbowski
Ford Motor Company
Fairlane Plaza South, Ste. 500
330 Town Center Drive
Dearborn, MI 48124

Dear Mr. Karbowski:

This responds to your May 3, 1996, facsimile asking whether New York=s proposed law requiring blind spot mirrors would be Aprohibited@ by our statute. Our answer is that the proposed State requirement would be preempted.

According to your letter, New York=s proposed law (9376--A, March 5, 1996) states, in relevant part:

[e]very motor vehicle sold after September first . . . shall be equipped with a blind spot mirror which is a convex mirror, circular in shape and 1.25 to 2.5 inches in diameter, that attaches directly on the standard side view mirror for cars, or of circular or rectangular shape, four inches to six inches in diameter or four inches by six inches, and is installed for trucks.

Federal Motor Vehicle Safety Standard No. 111, Rearview mirrors (49 CFR 571.111), prescribes performance requirements for side view mirrors on new cars and trucks. S5.2.1 of the standard specifies field of view requirements for the driver=s outside mirror on passenger cars and also specifies that the mirror shall be of Aunit magnification@ (i.e., flat). S5.3 provides the option of using a convex mirror in certain circumstances on the passenger side of a vehicle, and S5.4 specifies radius of curvature and other requirements for the convex mirror. S6, S7, and S8 specify requirements for truck rear view mirrors, including size. These sections require mirrors to be of unit magnification (with the exception of an option in S6 for mirrors complying with S5).

Section 30103(b) of 49 U.S.C. ''30101 et seq. (formerly '103(d) of the National Traffic and Motor Vehicle Safety Act) states:

when a motor vehicle safety standard is in effect under this chapter, a State . . . may prescribe or continue in effect a standard applicable to the same aspect of performance of a motor vehicle or motor vehicle equipment only if the standard is identical to the standard prescribed under this chapter.

New York=s Ablind spot mirror@ requirement appears to be preempted by Federal law. New York would be regulating the same aspect of performance (rear/side field of view) regulated by Standard No. 111. The state requirement would not be identical to the requirements of Standard 111. You state that complying with New York=s law would take some vehicles out of compliance with Standard No. 111. To the extent that New York=s requirement is inconsistent, it would be preempted.

It should be noted that NHTSA was petitioned to require convex rear view mirrors on the side mirrors, but denied this request. I have enclosed a copy of the denial for your information. (53 FR 45128)

If you have any further questions, please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosure

cc: Keith Cuddy Assembly Programming Counsel Rm. 513, The Capitol Albany, NY 12248

NCC-20:PAtelsek:6-2992:OCC# 11856:5/17/96 ref: FMVSS 111 cc: NCC-20 Subj/Chron, NCC-20 PJA, NPS-01, NSA-01 Interp.: 111, Redbook (2)

2

U:\NCC20\INTERP\111\11856-2.PJA

ID: 1982-1.13

TYPE: INTERPRETATION-NHTSA

DATE: 02/11/82

FROM: AUTHOR UNAVAILABLE; C. M. Price; NHTSA

TO: T. R. Lamia, Esq.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Thomas R. Lamia, Esq. Messrs. Paul, Hastings, Janofsky & Walker 1050 Thomas Jefferson Street, N.W. Washington, D.C. 20007

Dear Mr. Lamia:

This is in reply to your letter of December 16, 1981, submitting a petition to amend Federal Motor Vehicle Safety Standard No. 123, Motorcycle Controls and Displays.

You have asked for rulemaking to allow the installation of a speed control device on motorcycles which you believe is presently prohibited by the requirement that the manual twist-grip throttle be self-closing after its release. You have pointed out to us that such devices are "permitted" in motor vehicles covered by Standard No. 124, Accelerator Control Systems, but that no justification has been given for their "prohibition" by Standard No. 123.

Our review of both standards indicates silence on the question of speed control devices; they are neither permitted nor prohibited by either standard. Standard No. 123's requirement that the manual throttle be self-closing after release is conceptually identical to Standard No. 124's requirement that the throttle return to idle "whenever the driver removes the opposing actuating force" (paragraphs S5.1, S5.2). We interpret this specification in Standard No. 124 as a requirement to be met under the implied condition that the speed control device is disengaged. To remove any inconsistency between the two Federal accelerator control standards, we will extend this same interpretation to Standard No. 123; speed control devices are allowable and the throttle must return to idle after manual release when the device is not engaged.

This means that your petition is denied on the basis of mootness. Such a denial will allow us to prepare a Federal Register notice recording this fact and giving this interpretation a wide circulation.

Sincerely,

Courtney M. Price Associate Administrator for Rulemaking

December 16, 1981

National Highway Traffic Safety Administration 400 Seventh Street, S. W. Washington, D. C. 20590

Attention: Courtney Price Associate Administrator for Rulemaking

Dear Mrs. Price:

Pursuant to 49 C.F.R. Part 552, we hereby submit the enclosed "Petition to Initiate Rulemaking to Amend Federal Motor Vehicle Safety Standard 123 ('Motorcycle Controls and Displays')." We believe the Petition contains the necessary information and analysis to support commencement of the rulemaking proceeding sought by the Petition, and we respectfully request that the matter receive prompt attention and expeditious processing.

Please let us know if you have any questions or require any additional information.

Very truly yours,

Thomas R. Lamia of PAUL, HASTINGS, JANOFSKY & WALKER

TRL:mw

ID: 11502.DRN

Mr. Burt Jaquith
Tesa Meters, Inc.
Box 21519
Fort Lauderdale, FL 33335

Dear Mr. Jaquith:

This responds to your request for an interpretation of how NHTSA would classify your three wheeled motor vehicle, which is designed for mobility impaired drivers. As explained below, we concur with your opinion that your motor vehicle is a motorcycle.

Your letter explains that you are developing a Aspecialized vehicle for the wheel chair [sic] bound handicapped.@ Because of "the variable medical limitation" of your potential customers, each vehicle must be customized to the driver Aand would be a very limited production.@ The vehicle would have three wheels. Entry into and operation of your vehicle would be from a wheelchair. The vehicle's top speed would be limited to 39 miles per hour.

You informed Dorothy Nakama of my staff that your vehicle would be electrically powered and would not include a seat for the driver (because it is intended to be driven from a wheelchair). You further stated that although the vehicle will have no handlebars, it will be driven by a steering wheel and by a bar that can be manually pushed forward or back to regulate vehicle speed.

By way of background information, this agency has the authority under Federal law to issue Federal motor vehicle safety standards and related regulations applicable to new motor vehicles and new items of motor vehicle equipment. Vehicle and equipment manufacturers are responsible for "self-certifying" that their products comply with all applicable standards. They must also ensure that their products are free of safety-related defects. Once the vehicle or equipment is sold to the first retail customer, the product is no longer subject to the Federal safety standards and instead becomes subject to state law.

For the purposes of the Federal motor vehicle safety standards, NHTSA defines "motorcycle" as (49 CFR '571.3):

a motor vehicle with motive power having a seat or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground.

Your vehicle is a motorcycle because it has not more than three wheels. NHTSA considers the wheelchair seat that the driver sits in to be the functional equivalent of the "seat or saddle for the use of the rider."

Your vehicle must meet all safety standards applicable to motorcycles. However, I note that since your vehicle has no handlebars, it need not meet FMVSS No. 123, Motorcycle controls and displays, which applies to motorcycles equipped with handlebars. There are additional NHTSA requirements your company, the motorcycle manufacturer must meet. I am enclosing a copy of our fact sheet "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment," and another sheet that explains how NHTSA's regulations may be ordered.

A new manufacturer must submit certain identifying information to NHTSA in accordance with 49 CFR part 566, Manufacturer Identification (copy enclosed). The manufacturer must also meet 49 CFR part 567, Certification, and place on the motorcycle a label with information specified in 49 CFR section 567.4.

I hope this information is helpful. If you need any further information, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosure

ref:571.3 "motorcycle" d:5/3/96