ID: aiam4544

Dear Mr. Soh: This is in reply to your letter of June 20, 1988, wit respect to two motor vehicle lighting products which you intend to import into the United States. You have asked 'whether these devices require approvals from D.O.T.' First let me explain that the Department of Transportation does not 'approve' or 'disapprove' specific products. It does advise whether a product appears allowable under the National Traffic and Motor Vehicle Safety Act and the Federal Motor Vehicle Safety Standards. Your letter does not indicate whether you wish to market these devices as original equipment to be installed before initial sale of a motor vehicle, by either its manufacturer or dealer, or whether you intend to market them solely through the aftermarket. I shall address each situation. The Federal motor vehicle safety standard that applies to original equipment is Standard No. 108 Lamps, Reflective Devices and Associated Equipment. Paragraph S4.1.3 of Standard No. 108 allows additional motor vehicle equipment provided that it does not impair the effectiveness of the lamps and reflectors required as original equipment. Effectiveness may be impaired if the device creates a noncompliance in the existing lighting equipment or confusion with the signal sent by another lamp, or functionally interferes with it, or modifies its candlepower to either below the minima or above the maxima permitted by the standard. In addition, a motor vehicle must remain in conformance with Standard No. 108 (and all other safety standards) until its first purchase for purposes other than resale. There is no Federal standard that applies to your devices as aftermarket equipment, but the National Traffic and Motor Vehicle Safety Act prohibits a manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative, in whole or in part, original lighting equipment. Your first device is called a 'foglight converter.' The advertising literature attached states that its function is to turn 'the existing headlights...into foglights....' In our opinion, such a device would create a noncompliance with Standard No. 108 by rendering the headlamp function unavailable when the fog lamp converter is in use. We shall assume that the headlamp would be converted into a fog lamp meeting the specifications of SAE Standard J583 May81 Front Fog Lamps. None of the photometric test points of SAE J583 coincide with those specified for headlamps. Our further concern with this device is that a driver might fail to return to the headlamp mode from the fog lamp mode, and operate the vehicle with reduced frontal lighting. The situation differs with respect to the aftermarket. Under the National Traffic and Motor Vehicle Safety Act, a manufacturer, distributor, dealer, or motor vehicle repair business may not perform modifications that render inoperative, in whole or in part, equipment such as headlamps added pursuant to a Federal safety standard. We believe that the installation of the converter could affect the operability of the headlamp within the meaning of the statutory prohibition. However, we note that the foglight converter is advertised as 'easy for any driver to attach to any vehicle.' As an owner is not a manufacturer, distributor, dealer, or motor vehicle repair business, the owner is not restricted under Federal law from modifications to his vehicle. He is, however, subject to the laws of the States in which his vehicle is registered and operated. We are not conversant with how State lighting laws might affect use of the foglight converter, and you may wish to obtain an opinion from the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203. We have several other comments as well. The literature you enclosed depicts the foglight converter attached to what appears to be the European-designed H-4 bulb. Standard No. 108 does not permit headlamps with H-4 light sources to be sold for use on 4-wheeled motor vehicles. In addition, the application of the device where motion is translated from the lamp's exterior to the interior by a linkage in the bulb base would affect compliance with the requirement that the bulb base withstand a pressure differential of l0 psi. Additionally, creating a hole or passage for a linkage has the potential of rendering the headlamp noncompliant with Standard No. 108's requirements for certain environmental tests, such as resistance to dust, corrosion, and humidity. Your second device is a 'headlamp intensity modulator,' adjusting a headlamp beam 'automatically from low to high beam through a middle beam.' According to your literature, when a sensor notes the beams of an oncoming car 500 meters ahead the upper beam gradually passes through a middle beam and diminishes into a lower beam when the vehicles are 150 meters apart. This device is also advertised as capable of owner installation, and without the modification of any vehicle parts. The system appears to operate by a switch. This device directly conflicts with Standard No. 108, and its use would create a noncompliance with it. Headlamps are defined as producing upper and lower beams, and means must be provided for switching between these beams. Use of the device would alter upper and lower beam characteristics from those required by Standard No. 108, and in effect create an infinite number of beams while passing from a conforming upper beam at one extreme to a conforming lower beam at the other. This precludes its use as original equipment. We believe that its aftermarket legality would be limited. Although Federal law would not preclude an owner from installing it, the instructions are sufficiently complex that in our opinion many purchasers would seek help from a 'dealer' or 'motor vehicle repair business,' which could not be legally given. There would also remain the question of legality with State laws. These appear to be innovative devices and we regret that we cannot be more encouraging. Sincerely, Erika Z. Jones Chief Counsel;

ID: 15634-r.wkm

Mr. Richard C. Kempf
Manager Technical Legislation
Navistar International
Transportation Corporation
2911 Meyer Road
Post Office Box 1109
Fort Wayne, IN 46801

Dear Mr. Kempf:

Please pardon the delay in responding to your letter to me stating that Navistar interprets Federal Motor Vehicle Safety Standard (Standard) No. 121, Air Brake Systems, to provide that the antilock brake systems (ABS) required by the standard need not be operational when the vehicle is switched by the driver to the all-wheel drive (AWD) mode. Your interpretation is not correct.

You stated that certain vehicles equipped with AWD normally operate in the two-wheel drive mode, but the AWD mode is selectable by the driver for severe service operation. You also correctly pointed out that paragraph S6.1.11 of Standard No. 121, when relating to special drive conditions, provides that such vehicles are tested with the AWD mode disengaged.

Paragraph S5.1.6(a) of Standard No. 121 provides:

Each single-unit vehicle manufactured on or after March 1, 1998, shall be equipped with an antilock brake system that directly controls the wheels of at least one front axle and the wheels of at least one rear axle of the vehicle. Wheels on other axles of the vehicle may be indirectly controlled by the antilock brake system.

This provision clearly requires that all single-unit vehicles equipped with air brake systems must also be equipped with ABS.

This is a general requirement that applies under all conditions.

There is no exception from this requirement for vehicles equipped with AWD, whether being operated in the 2WD or AWD mode.

The requirements of section S5 are tested in accordance with the conditions set forth in section S6. Paragraph S6.1.11 of that section provides, as one of the road test conditions:

A vehicle equipped with an interlocking axle system or a front wheel drive system that is engaged and disengaged by the driver is tested with the system disengaged (emphasis added).

Thus, an interlocking axle, or AWD, system controlled by the driver is disengaged for the road tests conducted under subsection S6.1. That does not mean, however, that ABS may be disengaged whenever the AWD system is in operation. The equipment requirements of S5 are not limited by the road test conditions of S6.

In summary, the ABS required by Standard 121 may not be disengaged or disabled when the vehicle is switched into AWD mode, but a vehicle in the AWD mode would not be required to meet the road test requirements of subsection S6.1. While the ABS may not be disabled, however, its operation could be modified to better suit off-road conditions, such as construction, logging, or mining operations, when AWD is selected.

I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992.

Sincerely,
John Womack
Acting Chief Counsel
Enclosure
Ref:121
d.5/1/98

ID: nht89-1.64

TYPE: INTERPRETATION-NHTSA

DATE: 04/03/89

FROM: THOMAS C. GRAVENGOOD -- AGAPS PLASTICS INC

TO: NHTSA CHIEF CONSEL

TITLE: REF: FEDERAL MOTOR VEHICLE SAFETY STANDARD NO. 108 - HEATED SAFETY LIGHTS FOR VEHICLES DRIVEN IN WINTER WEATHER.

ATTACHMT: ATTACHED TO LETTER DATED 05/16/89 FROM STEPHEN P. WOOD -- NHTSA TO THOMAS C. GRAVENGOOD; REDBOOK A33; STANDARD 108; ALSO ATTACHED TO LETTER DATED 08/11/89 FROM STEPHEN WOOD TO GEORGE VANSTRATEN

TEXT: PER MY TELEPHONE CONVERSATION WITH MR. TAYLOR VINSON ON FRIDAY, MARCH 31, 1989, PLEASE FIND LITERATURE, SAMPLES AND SPECS OF OUR NEW HEATED SAFETY LIGHTS/LENSES.

FOR THOSE WHO DRIVE IN THE SNOW STATES IT OFTEN BECOMES DIFFICULT OR IMPOSSIBLE TO SEE THE LIGHTS OF VEHICLES AHEAD AND BEHIND. THE HEATED SAFETY LIGHT ELIMINATES THE ICE AND SNOW BUILD-UP FORMING THE CRUST THAT BLOCKS OUT VEHICLE LIGHTS.

AT THIS POINT, HEATED SAFETY LIGHTS HAVE BEEN PURCHASED BY THE STATE OF MICHIGAN FOR USE ON HEAVY SNOW REMOVAL EQUIPMENT, SCHOOL DISTRICTS FOR SCHOOL BUS LIGHTS, AND OTHER PURCHASES BY SEMI TRAILER REPLACEMENT PARTS DEALERS. THE HEATED SAFETY LIGHTS HAVE PROVED VIABLE AND ARE PERFORMING AS ADVERTISED IN THE ENCLOSED BROCHURE. THE LIGHTS ARE REORDERING AND NEW ORDERS ARE COMING IN FROM A SMALL AD PLACED IN A TRUCK MAGAZINE.

AGAP'E PLASTICS HAS BEEN APPROACHED BY VAN STRATEN TO TAKE OVER THE ASSEMBLYING OF THIS LIGHT TO INCREASE THE PRODUCTION NUMBERS AND SALES. WE ARE IN THE PROCESS OF SETTING UP A MULTIPLE PRODUCTION SYSTEM, AND ARE WORKING ON A NATIONAL MARKETING PROG RAM THAT WILL PUT US IN TOUCH WITH CUSTOMERS IN TWO DIFFERENT SEGMENTS OF SALES.

ALL LIGHTS, LENSES, AND MATERIALS TO ASSEMBLE THE HEATED SAFETY LIGHTS HAVE ALREADY BEEN CERTIFIED AND PASSED THE MOTOR VEHICLE SAFETY STANDARD NO. 108. WE HAVE BEEN ADVISED BY THE NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION THAT THERE IS NO MOTOR VEHICLE SAFETY STANDARD NO. FOR HEATED SAFETY LIGHTS. IN ORDER FOR US TO DO BUSINESS AT THE O.E.M. LEVEL WE REQUIRE A LETTER OF APPROVAL FROM YOU TO US THAT WE MAY PASS ON TO OUR CUSTOMERS SO THEY MAY START ORDERING AND WE MAY START PRODUCING.

IF YOU HAVE ANY QUESTIONS, CONTACT TOM GRAVENGOOD OR TOM ALT. AT AGAP'E PLASTICS, 616/363-1191. WE ARE LOOKING FORWARD TO HEARING FROM YOU IN THE VERY NEAR FUTURE. THANK YOU.

SINCERELY,

ID: aiam5357

"Dear Mr. Shetler: This is in reply to your letter of February 7, 1994 to the Associate Administrator for Enforcement requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108. So that we may serve you better in the future, please note that the Office of Chief Counsel is the one to which requests for interpretations should be addressed. You have asked whether the 'proposed application of a projector beam headlamp to a motorcycle' will meet the requirements of Standard No. 108. In this headlamp 'the projector beam (lower beam) is located on the left side and the high beam is on the right side.' You continue by saying that 'the outer lens of the headlamp assembly is symmetrically positioned about the vertical centerline,' and you ask whether the headlamp complies with the requirements of Table IV of Standard No. 108. Table III of Standard No. 108 requires a motorcycle to have at least one headlamp. Table IV requires the headlamp to be located 'on the vertical centerline, except that if two are used they shall be symmetrically disposed about the vertical centerline.' The device you describe contains the upper and lower beams in one housing and hence is a single headlamp. Although your projector beam headlamp would be mounted literally on the vertical centerline, the beams provided by the headlamp are located on either side of the centerline and are therefore asymmetrical in relation to the centerline of the motorcycle when either beam is activated. A redesign of the lamp so that its vertical centerline becomes its horizontal centerline and Line A becomes the vertical centerline would be a configuration that meets Table IV since both beams of the single headlamp would then be located on the vertical centerline. SAE J584 does not specify the location of one beam in relation to the other for dual beam motorcycle headlamps, i.e. whether one beam is to be mounted above or below the other. Your second question concerns an interpretation of S5.1.1.23. This paragraph provides an alternative for motorcycles to the headlamps specified by Table III, and allows a motorcycle to be equipped with 'one half of any headlighting system specified in S7 which provides both a full upper beam and full lower beam, and where more than one lamp must be used, the lamps shall be mounted vertically, with the lower beam as high as practicable.' You have asked whether this means that your proposed headlamp 'shall be mounted on the upper half and the high beam shall be on the lower half when using one half of any headlighting system specified in S7,' or 'is our proposed layout in the attachment acceptable?' As I have explained, your proposed layout in the attachment is not acceptable under Table IV without reorientation. The headlighting systems specified in S7 are those intended for four-wheeled motor vehicles (other than trailers). As we understand it, your proposed headlamp has been developed as a headlamp system for motorcycles and not as half of a headlamp system for vehicles other than motorcycles. Because motorcycle photometrics differ from those for vehicle other than motorcycles, your proposed headlamp could not be half of a system specified in S7 which may be used on motorcycles as an alternative to the headlamps specified by Table III. Sincerely, John Womack Acting Chief Counsel";

ID: nht76-2.24

DATE: 04/12/76

FROM: AUTHOR UNAVAILABLE; S. P. Wood for F. Berndt; NHTSA

TO: H. A. Heffron, Esq.

COPYEE: JOHN J. GIESGUTH

TITLE: FMVSS INTERPRETATION

TEXT: Re: Yankee Metal Products Corporation

Dear Mr. Heffron:

This is in reply to the petition of March 16, 1976, by your client Yankee Metal Products Corporation ("Yankee" herein) for an interpretation of 49 CFR 571.108, Motor Vehicle Safety Standard No. 108. Yankee seeks an interpretation "that the use of strobe type signal warning lamps on school buses is permissible provided that such lamps meet the specific performance requirements in S4.1.4 which incorporates SAE Standard J887."

Yankee has submitted a test report by Electrical Testing Laboratories, Inc. indicating conformance to SAE Standard J887 including its photometric requirements. Yankee has also submitted an opinion by a professional engineer that "the Yankee strobe lights tested by ETL meet the photometric requirements of SAE J887."

As you know, this agency does not "approve" specific lighting devices prior to their introduction into interstate commerce, and all that is legally required is that the manufacturer certify that its product meets all applicable Federal motor vehicle safety standards. The ETL report and professional opinion indicate that the design of the Yankee system complies with SAE J887, and thus they provide a basis upon which Yankee could certify that its system meets Standard No. 108. Therefore the use of its strobe type signal warning lamps appears to be permissible under Standard No. 108.

This means that the interpretation provided Mr. John J. Giesguth on December 9, 1975, does not apply to any strobe light system where an equivalency of conforming performance can be demonstrated, as Yankee appears to have done.

Sincerely,

LAW OFFICES HOWARD A. HEFFRON

202-872-0417

March 16, 1976

Frank Berndt, Esquire -- Acting Chief Counsel, National Highway Traffic Safety Administration

Re: Yankee Metal Products Corporation

Dear Mr. Berndt: I represent Yankee Metal Products Corporation of Norwalk, Connecticut in connection with the request for an interpretation of MVSS 108 submitted to your office today. Please communicate directly with me regarding this matter.

I would think that an early meeting between Yankee and NHTSA representatives to discuss the technical points presented and any related questions would be useful and help to expedite consideration of the matter and request that at an early date a conference for this purpose be scheduled.

Very truly yours,

Howard A. Heffron

ID: nht93-5.6

TYPE: Interpretation-NHTSA

DATE: July 2, 1993

FROM: Dave Beidleman -- Arizona Department of Transportation, Equipment Services

TO: Taylor Vinson -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7/29/93 from John Womack to Dave Beidleman (A41; Std. 108)

TEXT:

ADOT is in the process of having ten (10) dump trucks built for use within the Highways Division. We have encountered a problem with the placement of the rear identification lamps which, we hope, you can help solve. When the dump body on these units is raised, the rear cross sill comes in contact with the pintle hitch. The pintle hitch must remain positioned as is to properly mate with trailers in the fleet. The contractor has pre-punched holes for the identification lights in the rear cross sill of the dump body. We want to raise the center light of the 3-light identification light group by approximately 1-1/2 inches, and include a cut-out in the rear cross sill to provide necessary clearance at the pintle hitch when the dump body is raised. The outer lights of the 3-light identification light group cannot he raised due to the positioning of underbody tailgate release mechanism.

CFR 49 - 571.108(S5.3.1.1) states "...if motor vehicle equipment (e.g., mirrors, now plows, wrecker booms, hackhoes, and winches) prevents compliance with this paragraph by any required lamp or reflective devices, an auxiliary lamp or device meeting the requirements of this paragraph shall be provided." Can we proceed with this modification on this basis, without violating the requirements for identification lights established in FMVSS 108? (See attached drawing)

Drawing omitted. (Shows dump body - rear elect.)

ID: nht92-1.42

DATE: 12/04/92

FROM: STEPHEN P. WOOD -- ASSISTANT CHIEF COUNSEL FOR RULEMAKING, NHTSA

TO: GEORGE D. JAMES, JR. -- SAFETY CHAIRMAN, UNIT 169 WBCCI

ATTACHMT: ATTACHED TO LETTER DATED 10-24-92 FROM GEORGE D. JAMES, JR. TO PAUL J. RICE (OCC 7931)

TEXT: This responds to your letter of October 24, 1992, with respect to the Tekonsha electronic brake control. You believe that this agency has "approved" this brake control. Based on your experience towing a travel trailer, you expressed concern about the safety of these particular electronic brake controllers when in service on the public roads, because the stop lamps on the towed vehicle are not activated when the electronic brake control is used to apply the trailer's service brakes. You asked us to review our thinking and "rewrite the specs on this matter."

Let me begin by emphasizing that this agency has no authority to "approve," endorse, or offer assurances of compliance to any items of motor vehicle equipment. All that our letters of interpretation purport to do is to answer questions from manufacturers and other members of the public as to whether the manufacture, sale, and/or installation of equipment is permissible under applicable Federal laws and regulations. Our letter of April 3, 1992, to Echlin, Tekonsha's manufacturer, which you quote at one point, was a letter of interpretation, which concluded that "it now appears that the sale of the [Tekonsha] Control is not in violation of the National Traffic and Motor Vehicle Safety Act." This letter and conclusion can in no way be read as "approving," endorsing, or recommending the use of the Tekonsha system.

At this time, we do not have, nor are we aware of, any data indicating that there is a real-world safety problem created by use of the Tekonsha brake control. Hence, we have no reason to change the conclusion announced in the April 3 letter to Echlin about the legality of the Tekonsha control. We would be willing to review this matter again if data become available indicating a potential problem. Thus, if you or any member of your organization learns of any specific safety problems that have arisen for vehicles equipped with the Tekonsha control, please let us know.

I appreciate your interest in highway safety. It is only through the concern and support of citizens like yourself that this agency can achieve its goal of minimizing deaths and injuries on this nation's highways. Thank you for taking the time to let us know your thoughts on this matter.

ID: nht78-1.5

DATE: 03/22/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: J. Kawano

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. J. Kawano 1099 Wall Street, West Lyndhurst, New Jersey 07071

Dear Mr. Kawano:

This responds to your January 23, 1978, letter asking whether Safety Standard No. 205, Glazing Materials, would be applicable to tempered glass mounted on the outside panel of a vehicle "B-pillar" for ornamental purposes.

The answer to your question is no. Since there would be no danger that vehicle occupants would contact the ornamental glass, it would not have to comply with the performance and location requirements of Standard No. 205. This interpretation assumes, of course, that the glass is used only on the outside panel of a solid "B-pillar". Standard No. 205 would be applicable, for example, if the glass were used in a cut-out section of a "B-pillar", such that there was an interface of the glass with the vehicle occupant compartment.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

January 23, 1978

Mr. Joseph Levin, Chief Council National Highway Traffic Safety Adm. 400 Seventh Street, S.W. Washington, D.C. 20590

Interpretation Request of FMVSS 205

Dear Mr. Levin:

This is to confirm your interpretation as to whether tempered glass mounted on the outside panel of a B-pillar for ornamental purposes, as shown in Fig.1, falls into the application of FMVSS 205, "Glazing Materials."

The glass will be adhered, at every point, to the garnish which is bolted to the B-pillar outer panel. This can be observed in Fig.2 which shows the A-A section of Fig.1. In cases where the glass is broken into pieces, even though the glass has AS 3 performance equivalency, the fragment will not come out from the garnish because of the adhesion.

As we understand, FMVSS 205, "Glazing Materials," would not apply to such glass that is mounted simply for the purpose of ornamentation, as we mentioned above. However, your confirmation of our understanding will be very much appreciated.

Since this is an urgent matter, we would appreciate your expeditious interpretation.

Sincerely yours,

TOYOTA MOTOR SALES, U.S.A., INC.

J. Kawano Director/General Manager Factory Representative Office

JK:gc

ID: Ellerltr

Ms. Penny Eller
1006 South Road
High Point, NC 27262-7944

Dear Ms. Eller:

This responds to your telephone inquiry asking if a repair business or dealership is obligated to restore an automatic shoulder belt which is no longer functioning to its original condition or if it is permissible for the belt to be repaired so that it operates manually.

As discussed below, Federal law does not require that the automatic belt system be restored to its original condition. However, this subject area could be covered by State law.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles and new motor vehicle equipment. One of the standards we have issued is Standard No. 208, "Occupant Crash Protection" (49 CFR 571.208). During those model years in which automatic belt systems could be used to comply with Standard No. 208, manufacturers installed automatic belts in passenger cars and light trucks as one method of complying with the occupant protection requirements of Standard No. 208.

While the Federal motor vehicle safety standards apply only to new motor vehicles and new motor vehicle equipment, Federal law does limit the modifications that can be made by certain businesses to used vehicles. Manufacturers, distributors, dealers, and repair businesses are prohibited from "knowingly making inoperative" any device or element of a design installed on or in a motor vehicle in compliance with an applicable safety standard (49 U.S.C. 30122).

The "make inoperative" provision would prohibit a dealer or repair business from knowingly disabling safety equipment, such as an automatic belt, installed in compliance with an applicable safety standard. However, the provision does not impose an affirmative duty on dealers or other persons to repair equipment on a used vehicle that has ceased to function. Therefore, Federal law does not require restoration of a damaged or broken automatic belt in a used vehicle.

Despite the absence of any requirement in Federal law, State law may require restoration of automatic belts to their original condition. You may wish to contact the State of North Carolina to learn if there are any applicable laws or regulations. Additionally, you may wish to consult a private attorney about liability concerns, particularly if you sell the car.

In addition to the legal considerations, I note that, for vehicles being repaired for road-use, NHTSA recommends the repair, restoration, or replacement of all safety systems that may have been damaged in a crash or has otherwise ceased to function. These systems include the safety belts, air bag systems (including sensors), built-in child restraints, and other vehicle systems such as brakes, accelerator controls, transmission gear and "park" function, etc.

I hope this information is helpful. If you have further questions, please feel free to contact Otto Matheke of my staff at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:208
d.6/20/00

ID: aiam2229

Dear Mrs. Anderson: I am writing in response to your March 9, 1976, telephone conversatio with Mark Schwimmer of this office concerning the meaning of 'GVWR' as it appears in Federal Motor Vehicle Safety Standard No. 301-75, *Fuel System Integrity*.; 'GVWR' or 'Gross vehicle weight rating' is defined in 49 CFR 571.3 as: >>>the value specified by the manufacturer as the loaded weight of single vehicle.<<<; One constraint on this specification is found in S567.4(g)(3) of 49 CF Part 567, *Certification*, which requires that the GVWR shall not; >>>be less than the sum of the unloaded vehicle weight, rated carg load, and 150 pounds times the vehicle's designated seating capacity... .<<<; An information sheet entitled 'Where to Obtain Federal Motor Vehicl Safety Standards and Regulations' is enclosed for your convenience. If you have any further questions, please do not hesitate to write.; Yours truly, Richard B. Dyson, Assistant Chief Counsel