ID: aiam3566

Dear Mr. Siegenthaler: This is in reply to your letter of May 18, 1982, 'regarding th legality of placing a red alternator warning light on the side of a truck refrigeration unit.'; Because the warning light is not required as original motor vehicl lighting equipment under Federal Motor Vehicle Safety Standard No. 108, it is subject only to the prohibition of paragraph S4.1.3 that it not impair the effectiveness of lighting equipment which the standard requires. The required lighting equipment on the sides of trucks are side marker lamps and reflectors, amber to the front as far as practicable and red to the rear as far as practicable. If the truck's overall length is 30 feet or greater, intermediate lamps and reflectors, amber in color, must be added at or near the mid-point between the front and rear markers.; You have not stated where the warning light will be located, nor th length of the truck on which it would be mounted. To avoid any suggestions of conflict we recommend, if the lamp is to be mounted on a truck carrying intermediate side markers, that it be as close to the rear as practicable. On a short truck equipped with only front and rear side marking devices any location from the mid-point rearward would be acceptable. These locations should also satisfy any questions State authorities may have.; Sincerely, Frank Berndt, Chief Counsel

ID: nht89-2.52

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/89

FROM: MICHAEL E. KASTNER -- DIRECTOR OF GOVERNMENT RELATIONS NTEA WASHINGTON OFFICE

TO: SAMUEL K. SKINNER SECRETARY OF TRANSPORTATION U.S. DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/24/89 EST; FROM JEFFREY R. MILLER -- NHTSA TO MICHAEL E. KASTNER -- NATIONAL TRUCK EQUIPMENT ASSOCIATION; REDBOOK A34; STANDARD 204; LETTER DATED 08/26/87 FROM ERIKA Z. JONES -- NHTSA TO TAK FUJITANI; LETTER DATED 06 /29/89 FROM SAMUEL K. SKINNER -- DOT TO ERNEST F. HOLLINGS -- SENATE

TEXT: Dear Mr. Secretary:

I am writing on behalf of the National Truck Equipment Association ("NTEA"), which represents over 1,400 companies involved in the manufacture and distribution of commercial and vocational trucks, to express our concern with the Department of Transpor tation's ("DOT" or the "Department") intention to extend regulations that currently apply only to passenger vehicles to the full range of light trucks including those that are not used for family transportation.

Recently you received from Senator Hollings, Chairman of the Senate Commerce Committee, and others on the Committee, a letter requesting that the Department, and the National Highway Traffic Safety Administration ("NHTSA" or the "Agency") in particula r, take steps to apply certain passenger car Federal Motor Vehicle Safety Standards ("Safety Standards" or "FMVSS") to light trucks, vans and sport-utility vehicles. In response, you indicated that the Department would make recommendations to the White House concerning such rulemaking initiatives. Senator Hollings' request was based on the fact that such vehicles "are being used primarily for transporting families rather than hauling freight."

In light of two rulemaking proceedings completed by NHTSA within the past 18 months, in which the Agency failed adequately to distinguish between vehicles used for "transporting families" from those used for "hauling freight," the NTEA questions wheth er the Agency has sufficient understanding of the relevant facts and law to pursue such new rulemaking initiatives fairly and objectively. Although the Agency has made an effort to understand the multi-stage manufactured truck industry, we fear that, unt il the Agency fully appreciates the manner in which trucks are produced, it will continue to adopt regulatory requirements that impose impossible burdens on the small- and medium-sized companies in the truck body and equipment industry.

In November 1987, the Agency published two final rules that resulted in the dynamic testing (i.e., crash testing) requirements of FMVSS 204 (steering column rearward displacement) and 208 (occupant crash protection) being applied to a wider array of l ight-truck types and an increased population of multi-stage truck manufacturers. The NTEA submitted a petition for reconsideration of each final rule. NHTSA denied the NTEA's petitions for reconsideration for FMVSS 208 in December 1988 and for FMVSS 20 4 in June 1989.

NTEA argued in its petitions for reconsideration that dynamic testing cannot reasonably and practicably be applied to the small- and medium-sized businesses that produce work-related light trucks manufactured in two or more stages. NHTSA rejected the NTEA's arguments, primarily on the basis that, under the present Safety Standard certification requirements, final-stage manufacturers could effectively avoid certifying to Safety Standards that include dynamic testing requirements. NHTSA expressly ackn owledged that final-stage manufacturers "do not have the engineering or financial resources to conduct dynamic testing."

The alternatives to dynamic testing offered by NHTSA to the truck body and equipment industry demonstrate that the Agency misunderstands its own regulations and the manner in which commercial vehicles are produced in the United States. These misunder standings, which we believe render the Agency's rulemaking arbitrary and capricious, include the following threshold issues:

1. NHTSA has Misinterpreted its Certification Regulations

According to NHTSA, "[t]he final-stage manufacturer need not conduct any crash testing or engineering analyses if it completes its vehicles within the limits specified by the incomplete vehicle manufacturer. . . . When the vehicle is completed within the incomplete vehicle manufacturer's specification, the final-stage manufacturer need only so state on its certification label and the responsibility for the vehicle's conformity with the standards rests entirely on the incomplete vehicle manufacturer. " 54 Fed. Reg. 24348 for FMVSS 204 and similarly at 53 Fed. Reg. 50225 for FMVSS 208.

In the denial of NTEA's petition for reconsideration of FMVSS 208, NHTSA states that "[t]hose provisions [the certification regulations of 49 C.F.R. Parts 567 and 568] require the incomplete vehicle manufacturers (companies such as Chrysler, Ford, and General Motors) to certify the compliance of their incomplete vehicles, and require the final-stage manufacturers to certify the compliance of the components they mount on the vehicle and the effect of the mounting, and thus obtain effective certificati on of the completed vehicle without imposing unreasonable burdens on either incomplete or final-stage manufacturers." 53 Fed. Reg. 60226. (Emphasis added.)

NHTSA mistakenly concludes that small businesses completing vehicles need not certify to Safety Standards that include dynamic testing requirements. This conclusion is based in part on NHTSA's incorrect belief that the incomplete vehicle manufacturer is required to certify compliance with FMVSS 204 and 208 in all cases, and that the final- stage manufacturer need not certify to these Safety Standards if vehicles are completed within the limits established in the incomplete vehicle document. This co nclusion is contrary to the plain language of NHTSA's own regulations.

The small businesses that complete commercial and vocational vehicles on chassis other than a chassis-cab, (i.e., chassis without an enclosed cab compartment, including cut-aways, chassis cowls and stripped chassis) are required to certify the complia nce of the completed vehicle to all applicable Safety Standards, including those which require dynamic testing. 49 C.F.R. 567; See, also, letter from Erika Jones, NHTSA Chief Counsel, to Tak Fujitani, Project Manager, Inspection Services, Office of Flee t Administration, State of California (Aug. 6, 1987). Accordingly, final-stage manufacturers cannot escape the certification obligation when completing vehicles on these types of chassis. Final-stage manufacturers cannot, as NHTSA suggests, merely "pass through" the incomplete vehicle manufacturer's certification for non-chassis-cab incomplete vehicles because none exists. As the NHTSA Chief Counsel has pointed out, "the [incomplete vehicle] document is not a certification." Id. Incomplete vehicle ma nufacturers need only certify incomplete vehicles that are chassis-cabs (See 49 C.F.R. 567 and 568.), and provide an incomplete vehicle document for all incomplete vehicles, which "document is not a certification."

Thus, NHTSA's suggestion that small businesses involved in the production of trucks can avoid certifying to Safety Standards that include prohibitively costly, crash testing and/or engineering analyses (such as required by FMVSS 204 and 208) by comple ting vehicles within the parameters of the incomplete vehicle document is simply not correct for a substantial population of commercial and work-related vehicles.

2. NHTSA Operates Under a Clear Misunderstanding of the Truck Body and Equipment Industry

In its denials of the NTEA's petitions for reconsideration, NHTSA states: "When a final-stage manufacturer is unable to complete the vehicle within the specifications established by the incomplete vehicle manufacturer, the final-stage manufacturer can build the vehicle on a heavier chassis, and remain within the limits specified for that heavier chassis. Again, the final-stage manufacturer would not have to conduct any dynamic testing or engineering analyses prior to certifying that the vehicle compl ies with the safety standards." (53 Fed. Reg. 50225 and 54 Fed. Reg. 24348). NHTSA further states that "[i]t is also possible that the switch to a higher rated chassis would result in the completed vehicle not being subject to the dynamic testing require ments . . . (54 Fed. Reg. 24346-24347)."

NHTSA's statement that small businesses can avoid certifying to Safety Standards that include dynamic testing requirements by building on a heavier chassis demonstrates that NHTSA does not understand how commercial and vocational vehicles (i.e., all l ight trucks other than unmodified pickups and vans) are produced. In virtually all cases, the customer and the chassis dealer, without input from the final-stage manufacturer, select the chassis to be used for the work-related vehicle and the specificat ions for the completion of the vehicle. With respect to the sale of new commercial and vocational vehicles, the final-stage manufacturer is typically a subcontractor to the dealer. The final-stage manufacturer does not have the option to change the cus tomer's vehicle specifications so as to avoid a certification obligation. NHTSA obviously does not fully appreciate the fact that commercial and vocational vehicles are custom ordered and built to buyer specifications in virtually all cases, and that the small businesses that complete such vehicles act almost exclusively as subcontractors. NHTSA's suggestion that building on a heavier chassis as an alternative to certifying compliance with Safety Standards has absolutely no basis in the reality of the marketplace.

Thus, as the foregoing demonstrates, both of the alternatives NHTSA offers to small businesses to avoid the dynamic testing obligation -- completing vehicles within the incomplete vehicle documentation specifications or building on a heavier chassis - - fail to provide adequate relief to the small businesses that complete commercial and vocational light trucks. In light of NHTSA's acknowledgement that intermediate-and final-stage manufacturers and vehicle alterers cannot, as a group, comply with dyna mic testing requirements, the absence of meaningful alternatives places these businesses in an untenable position. A safety standard that cannot be complied with is neither reasonable nor practicable.

Although this letter has focused only on two inadequacies in the rulemaking record of FMVSS 208 and 204, other significant flaws exist. These include, but are not limited to, NHTSA's failure to conduct any comprehensive study of the multi-stage manuf acturing truck industry and the work-related vehicles produced (other than NHTSA's apparent reliance on limited data submitted nearly a decade ago by a now defunct trade association) in the course of its rulemaking.

We trust that the issues raised in this letter demonstrates the validity of the truck equipment industry's concern over continued rulemaking that would extend passenger-car Safety Standards to all light trucks. We fear that such rulemaking will resul t in Safety Standards that are overly broad and arbitrarily reach commercial/vocational trucks.

The NTEA agrees with Senator Hollings that vehicles designed, marketed, manufactured and used primarily as passenger or family transportation vehicles should be subject to Safety Standards adopted for passenger cars regardless of whether the vehicles are commonly thought of as automobiles, light trucks, vans or sport-utility vehicles. However, vehicles designed, marketed, manufactured and used primarily for commercial, work-related, vocational or emergency purposes, and not for personal transportati on should not be regulated in the same manner as passenger-oriented cars or trucks. While the users of such commercial vehicles should be assured of their safety, in the absence of accident and fatality data suggesting that identical regulation is neces sary and appropriate, the Safety Standards that apply to passenger-oriented vehicles should not be applied arbitrarily to work-related trucks. Moreover, where it is determined that particular Safety Standards should apply to all passenger-oriented vehic les and work-related trucks, the dynamic testing requirements that are imposed and may be appropriate for single-stage, assembly-line produced cars and trucks cannot and should not be imposed on multi-stage produced trucks because of the nature of the mu lti-stage manufacturing truck industry. We believe that this view is consistent with the sentiments of the Senate and is consistent with the spirit of the National Traffic and Motor Vehicle Safety Act.

We recognize that you must make recommendations to the White House concerning the application of passenger car Safety Standards to light trucks, vans and sport utility vehicles. We urge you, however, to reexamine the previous two rulemaking proceedin gs and conduct a comprehensive study of the unique problems encountered by multi-stage manufacturers in certifying compliance with applicable Safety Standards before undertaking any of these new rulemaking initiatives.

Representatives from the NTEA would be happy to meet with you to provide more detail on the truck body and equipment industry and its concerns. Please feel free to contact me in Washington, D.C. at 628-2010.

Sincerely yours,

ID: aiam0916

Dear Mr. Pomeroy: This is in response to your letter of November 3, 1972, to our Regiona Administrator, Region IX, San Francisco, California office concerning the test procedures of Federal Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.'; You state that in the test procedure described in paragraph S5.3, yo see 'no room for the bunsen burner to stand' when a carpet specimen 14 inches long is in the center 'of all inside dimensions of the box.' The source of your interpretive difficulty with respect to the test procedure appears to be your assumption that the carpet specimen should be placed in the center 'of all inside dimensions' of the test cabinet. The test procedure only specifies that the specimen be mounted 'in a horizontal position, in the center of the cabinet.'; The standard does not specify a particular means for positioning th bunsen burner tube or for positioning the test specimen above the top of the burner tube, because there are a variety of satisfactory means used for this purpose. The specimen holder should be in the center of the cabinet with the closed end contacting the end of the cabinet.; Since the bunsen burner is used with the air inlet shutoff, it is i effect a 3/8 inch inside diameter tube with a metering valve. There is no reason why such a device, without the bunsen burner base, may not be permanently mounted inside the cabinet for convenience.; You also ask whether bottled propane gas can be substituted for natura gas. The answer to this question is that your choice of what gas to use is a matter within your own discretion. The standard simply specifies that for our compliance testing, the gas supplied to the burner will have 'a flame temperature equivalent to that of natural gas.'; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;

ID: aiam5589

Dear Ms. Dawson: This responds to your letter to Walter Myers of thi office regarding the May 9, 1995, amendment of Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus Window Retention and Release. I apologize for the delay in responding. For your future reference, Mr. Myers is no longer assigned to our school bus standards. You may address requests for interpretation directly to me. The May 9 amendment (60 FR 24562) to FMVSS No. 217 permitted, among other things, bus manufacturers to meet the additional emergency exit area (AEEA) requirements of S5.2 by permitting manufacturers to install two emergency exit windows as an alternative to an emergency exit door. You asked what the location requirements (fore and aft) are for the emergency windows that are used as the first additional emergency exit. FMVSS No. 217 contains no explicit fore and aft location requirements for the two additional emergency exit windows. However, the intent of the final rule was to substitute the location requirements of the side exit door when the windows are used to satisfy the requirement for the first additional emergency exit. This intention is reflected in the use of the conjunctive word 'or' in Tables 1 and 2 of the May 9, 1995, amendment. If a left side exit door would have been installed pursuant to S5.2.3.1(a)(2)(i), then S5.2.3.2(a)(2) requires that it be located as near as practicable to the midpoint of the passenger compartment. The same fore-aft location should be used for the windows. In cases where the fore-aft location is not specified, such as a right side exit door installed pursuant to S5.2.3.1(b)(2)(i), then the windows should be placed so as to provide bus passengers with maximum accessibility to an emergency exit, in accordance with what is reasonable and practicable. Also note the explicit location requirement in S5.2.3.2(c) that exit windows be evenly divided between the left and right sides of the bus. For example, if two exit windows are used instead of a left side exit door, they should be placed on opposite sides at the midpoint of the bus. I hope this information will be of assistance to you. Should you have any further questions or seek additional information, please feel free to contact Paul Atelsek at this address or by calling (202) 366-2992. Sincerely, John Womack Acting Chief Counsel;

ID: aiam5558

"Dear Mr. Tolley: This responds to your letter of April 28, 1995 asking for an interpretation of the torque deflection test specified in paragraph S7.8.5.1 of Motor Vehicle Safety Standard No. 108. The second sentence of this paragraph states that 'The downward force used to create the torque shall be applied parallel to the aiming reference plane, through the aiming pads, and displaced forward using a lever arm such that the force is applied on an axis that is perpendicular to the aiming reference plane and originates at the center of the aiming pad pattern.' You believe that the instructions for performing the test are not sufficiently precise and can be interpreted in different ways. Specifically, you are concerned that the standard fails to adequately define the center of rotation of force, which is necessary to determine the downward force applied to the headlamp. We agree with you, and are examining ways in which the standard might be amended to address the problem you have brought to our attention. Noting that you have presented four possible answers (as well as 'some other point'), our comment is that, until NHTSA clarifies the matter, a manufacturer should choose a center of rotation that appears the most appropriate for the design of mechanically aimable headlamp under consideration, in certifying that the headlamp meets all applicable Federal motor vehicle safety standards. I am sorry that we could not be more helpful at this point. If you have any questions you may refer them to Taylor Vinson of this office (202-366-5263). Sincerely John Womack Acting Chief Counsel";

ID: aiam3902

Dear Mr. Chikada: This is in reply to your letter of January 18, 1985, to Mr. Vinson o this office asking for three interpretations of Motor Vehicle Safety Standard No. 108 with respect to motorcycle lighting.; Your first question is about the location of rear turn signals. Tabl IV of Standard No. 108 requires that rear turn signal lamps on motorcycles have a minimum horizontal separation distance 'centerline to centerline' of 9 inches. You have asked whether this may be interpreted as filament center to filament center., The answer is no. The phrase means the distance from the geometric center of one lamp to the geometric center of the other.; Your second questions concerns the permissibility of an arrangement o lamps on the rear of a motorcycle. There would be a two-compartment combination stop/tail lamp on the vehicle centerline with separate combination lamps below it on either side of the centerline. The distance between filament centers of the separate lamps would be a maximum 16 inches, and there would be the same distance between the filament centers of each separate lamp and the compartment above it belonging to the two- compartment lamp. You have asked whether this is permissible if the minimum design candlepower complies with requirements for three lighted sections in SAE J585e and SAE J586c, and the effective projected luminous lens area of each compartment or lamp is at least 3 1/2 square inches. This arrangement, though unusual, appears to be acceptable. SAE Standard J586c *Stop Lamps* and SAE J585e *Tail Lamps* state that if multiple compartment or multiple lamps are used, and the distance between filament centers does not exceed 16 inches for three compartment or lamp arrangements, the combination of the compartments or lamps must be used to meet the photometric requirements for the corresponding number of lighted sections. Your design has four lighted sections, where as the SAE Tables provide values for only three. In our opinion, your design would be acceptable provided that each of the four compartments meets the minimum value specified for test points in a section when there are three lighted sections.; Your final question concerns a combination stop/taillamp of fou sections, two each on either side of the vertical centerline. Though no distance is given for the filament centers, they appear to be closer than 16 inches. You have asked if this design is permissible provided it meets the requirements for three lighted sections, and the effective projected luminous lens area of each compartment is not less than 3 1/2 square inches. The answer is yes, this is acceptable provided that each of the four compartments meets the minimum value specified for test points in a section when there are three lighted sections.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam0928

Dear Mr. Meyer: A review of correspondence we sent you on October 6, 1972, (in respons to your letter of September 26, 1972, concerning child seating systems you plan to import), has revealed that one statement we made should be clarified.; In the second paragraph of our letter we stated that each 'seat must b labeled or tagged with a certification that it conforms to all applicable Federal motor vehicle safety standards.' Standard No. 213 (49 CFR 571.213), which applies to child seating systems, does require each child seating system to be labeled with information regarding its safe use, and we refer you to the standard for these requirements. However, with respect to certification, manufacturers are not limited to the method specified in our October 6, 1972, letter (viz., attaching a label to the seat), but may certify in other ways as well. For example, Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403), on which the certification requirement is based, states that the certification may also be placed on the outside of the container in which the item is delivered.; We regret that our former letter was incomplete in this regard. Sincerely, Richard B. Dyson, Assistant Chief Counsel

ID: aiam5491

Dear Mr. Liebscher: We have reviewed your application of January 16 1995, for temporary exemption of the M1-6 electric passenger car from six Federal Motor Vehicle Safety Standards, on the basis that compliance would cause Electric Car Company ('Electric Car') substantial economic hardship. We need some additional information before we are able to consider the application further. A hardship applicant must provide corporate balance sheets and income statements for the three fiscal years preceding the filing of the application. You have filed statements for E.T.C. Industries and only for two years, those ending December 31, 1992, and December 31, 1993. This is acceptable since your submission indicates that E.T.C. Industries (apparently a Canadian corporation) is the parent of Electric Car (a Nevada corporation incorporated on November 24, 1993), and that 'the consolidated financial statements that you have provided us include the accounts of Electric Car . . . .' We would like to have balance sheets and income statements for Electric Car for the year ending December 31, 1994, but if these are not yet available, we would be willing to accept statements for E.T.C. Industries (or its predecessor Bradsue Resources, Ltd.) for the year ending December 31, 1991. If the information reflected in the financial statements is given in Canadian dollars, please provide a key indicating the value in American dollars on December 31 of each year for which the information is provided. In order to grant a hardship application, the Administrator must find that an applicant has tried to comply in good faith with each standard for which exemption is requested. Your application contains no information upon which the Administrator could make such a finding with respect to any of the six standards for which you seek exemption. In spite of your confidence about the MI-6's performance in a 30 mph barrier impact, the fact that the MI-6 uses equipment installed in motor vehicles that are certified as meeting the Federal motor vehicle safety standards does not mean that the MI-6 will meet any of the six standards with the equipment installed. We therefore suggest that you supplement the application with information demonstrating that you have examined each of the six standards in some detail, and have made a study of possible compliance problems and possible solutions to them. It is permissible to ask to be excused from only a portion of a standard, and you may find, after studying your problems, that you will be able to narrow your requests for exemption from Standards No. 201 and 208. We assume with respect to the latter that you are concerned with the airbag requirements. Although your letter speaks of 'restraint systems', we would like your further identification of them as two-point (lap belt) or three-point (lap and shoulder belt) systems. Although you appear to be a manufacturer in the start-up stage and one whose total motor vehicle production in the year preceding the filing of the application was far less than 10,000, you have omitted to provide the number of motor vehicles that you produced in 1994 which is information that we require. Please do so in your response to this letter. When we have received this information, we shall prepare a notice requesting public comment which will appear in the Federal Register. We shall notify you when the Administrator has made a decision. We expect this to be three to four months after we have received your further submission. If you have any questions on our requirements, you may call Taylor Vinson of this Office (202- 366-5263). Sincerely, Philip R. Recht Chief Counsel;

ID: aiam1506

Dear Mr. Olson: This responds to your April 2, 1974, request for a ruling on whethe trolley and motor buses equipped with air brake systems and dynamic electric or hydraulic devices are required to be equipped with anti-lock equipment.; Standard No. 121, *Air brake systems*, requires stopping distanc performance which must be met by any bus equipped with air brakes, whether or not it is equipped with supplementary dynamic braking means, and the stops must be made with only controlled wheel lockup over 10 mph. Although the standard does not require antilock devices, many manufacturers have indicated they will use antilock devices to meet this requirement.; In evaluating a vehicle's compliance with the stopping distanc performance requirements of S5.3 and S5.7.2.3, auxiliary braking devices may be utilized in making the stops provided such devices are engaged by means of the same service brake pedal or parking brake control that operates the air brakes. It should be noted, however, that these stops must be made with the transmission selector control in neutral or the clutch disengaged (S6.1.3).; Please write again if this or other difficulties arise in th certification of your buses.; Sincerely, Richard B. Dyson, Acting Chief Counsel

ID: aiam1356

Dear Mr. Olson: This responds to your April 2, 1974, request for a ruling on whethe trolley and motor buses equipped with air brake systems and dynamic electric or hydraulic devices are required to be equipped with antilock equipment.; Standard No. 121, *Air brake systems*, requires stopping distanc performance which must be met by any bus equipped with air brakes, whether or not it is equipped with supplementary dynamic braking means, and the stops must be made with only controlled wheel lockup over 10 mph. Although the standard does not require antilock devices, many manufacturers have indicated they will use antilock devices to meet this requirement.; In evaluating a vehicle's compliance with the stopping distanc performance requirements of S5.3 and S5.7.2.3, auxiliary braking devices may be utilized in making the stops provided such devices are engaged by means of the same service brake pedal or parking brake control that operates the air brakes. It should be noted, however, that these stops must be made with the transmission selector control in neutral or the clutch disengaged (S6.1.3).; It can be foreseen that at least one difficulty may arise in testin with supplementary brake systems. S6.3 requires that the transmission be in neutral or the clutch be disengaged during deceleration, which might eliminate the torque from your dynamic brake.; Please write again if this or other difficulties arise in th certification of your buses.; Sincerely, Lawrence R. Schneider, Chief Counsel