ID: nht88-3.25

TYPE: INTERPRETATION-NHTSA

DATE: 08/26/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: GLENN L. DUNCAN, -- THORNE, GRODNIK & RANSEL

TITLE: NONE

ATTACHMT: LETTER DATED 08/30/79 TO ROBERT J. WAHLS' FROM FRANK A. BERNDT; LETTER DATED 04/28/77 TO GORDON P. CRESS FROM FRANK A. BERNDT, STANDARD 210; LETTER DATED 02/01/88 TO ERICA Z. JONES FROM GLENN L. DUNCAN RE UNITED TOOL AND STAMPING INC FMVSS 207 SEATING SYSTEM; LETTER DATED 11/16/87 TO ERICA Z. JONES FROM GLENN L. DUNN RE FMVSS 207 SEATING SYSTEM OCC - 1278

TEXT: Dear Mr. Duncan:

This responds to your letter concerning situations in which seats tested for compliance with Safety Standard No. 207, Seating Systems, bend or deform when subjected to the required test forces specified in the standard. You asked whether NHTSA would con sider a seat as passing Standard No. 207 if the seat "gives," but does not separate or break free from the floor. I regret the delay in responding.

The requirements with which you are concerned are set forth in section S4.2 of Standard No. 207. That section provides in pertinent part:

S4.2 General performance requirements. When tested in accordance with S5., each occupant seat, other than a side-facing seat or a passenger seat on a bus, shall withstand the following forces.

(a) In any position to which it can be adjusted--20 times the weight on the seat applied in a forward longitudinal direction;

(b) In any position to which it can be adjusted--20 times the weight on the seat applied in a rearward longitudinal direction;

* * * * *

(d) In its rearmost position--a force that produces a 3,300 inch-pound moment about the seating reference point for each designated seating position that the seat provides, applied to the upper cross-member of the seat back or that appear seat back, i n a rearward longitudinal direction for forward facing seats and in a forward longitudinal direction for rearward-facing seats.

The agency answered similar questions in letters dated April 28, 1977 and August 30, 1979 to Mr. Gordon P. Cress and to Mr. Robert Wahls, respectively. (Copies enclosed.) In these letters, the agency stated

2 that NHTSA allows some deformation of the seats during the force test, provided that "structural integrity of the seats is maintained." The structural integrity of a seat is determined by the extent to which permanent deformation or separation of seat components and/or seat to floor attachments result from the applied test forces. Examples of possible noncompliances include the following occurring during the application of a forward or rearward load:

(a) the seat frame releases from its adjusted position;

(b) the seat frame or seat adjusters detach from the test vehicle floorpan;

(c) the seat frame detaches from the seat adjuster mechanism;

(d) the seat adjuster mechanism separates; or,

(e) the hinged seat restraining device disengages, or detaches from the seat frame.

Other examples of possible noncompliances are the rear seat back or cushion frame detaching from the test vehicle structure during the application of the specified load, or the folding seat back restraining device releasing from its preset position durin g application of a forward load.

Further, as stated in the two enclosed letters, it has been the longstanding position of the agency that seats which displace to an extent that NHTSA determines occupant safety is threatened would not be in compliance with Standard No. 207.

I hope this information is helpful. Please contact my office if you have further questions.

ENCLOSURES

Sincerely,

ID: nht88-3.26

TYPE: INTERPRETATION-NHTSA

DATE: 08/26/88

FROM: RE MORGAN -- MILEAGE TIRE ENGINEERING GOODYEAR TECHNICAL CENTER

TO: MARVIN ORNES -- MANAGER, TECHNICAL SUPPORT REGIONAL TRANSPORTATION DISTRICT

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12/09/88 FROM ERIKA Z. JONES -- NHTSA TO JACK MCCROSKEY AND GLENDA SWANSON LYLE, REDBOOK A33, STANDARD 119; LETTER DATED 09/13/88 FROM JACK MCCROSKEY AND GLENDA SWANSON LYLE TO LARRY COOK -- NHTSA, OCC 2539; LETTER DATE D 09/09/87 FROM R. E. MORGAN TO R. ROGERS RE GOODYEAR MILEAGE TIRES; REF BRUCE RUMAGE PHONE CALL; BOOKLET FROM REGIONAL TRANSPORTATION DISTRICT DATED 12/01/87 EST

TEXT: Dear Mr. Ornes:

Goodyear supplies basically two type of tires for Intra City Service. City Cruiser DXT and the City Cruiser XT tire. Both are produced in the same mold and have the same number of plies.

They both are designed for identical service; but the difference comes in the amount of "Tread Rubber." DXT tires have a total of 1.40 inches of tread rubber and the XT tire has 1.18 inches. Marked on the sidewall of the DXT tire is the Max speed of 35 MPH, and on the XT is 55 MPH. The DXT may be used at higher speeds; but not for sustained operation.

Once the tread rubber is worn down for either regrooving or recapping they both become the same tire carcass and may be used for 55 MPH service. Recapping process does not add the extra undertread on the carcass but the regular amount, so the tires will run safely at the 55 MPH speed.

Please contact us if more explanation is needed.

Sincerely,

ID: nht88-3.27

TYPE: INTERPRETATION-NHTSA

DATE: 08/30/88 EST

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: FRANK REYNOLDS -- F. E. REYNOLDS ASSOCIATES

TITLE: NONE

ATTACHMT: LETTER DATED 06/20/88 FROM FRANK BERNDT TO JAMES TYDINGS -- THOMAS BUILT BUSES

TEXT: Dear Mr. Reynolds:

This is in response to your telephone conversation with Marvin Shaw of my staff, seeking a clarification of my June 16, 1988 letter concerning school bus mirrors under Highway Safety Program Guideline No. 17. Specifically, you asked about the meaning of the phrase, "area in front of the bus," as used in section S9.2(b) of Standard No. 111, Rearview Mirrors (49 CFR @ 571.111). In your telephone conversation, you stated that a NHTSA staff person told you in a previous telephone conversation that NHTSA h ad defined this phrase to mean "the area three feet in front of the bus." NHTSA has never so interpreted this phrase in Standard No. 111.

For your information, I am enclosing a June 20, 1980 letter to James Tydings that sets forth the agency's interpretation of S9.2(b) of Standard No. 111. This letter notes that the area of concern in S9.2(b) is the region in front of the bus where a drive r is not able to see directly a school age child. As explained in the letter and an earlier notice (40 FR 33829, August 12, 1975), the purpose of a crossview mirror is to "address special problems of driver visibility associated with pupil transportatio n," and this type of mirror "allows the bus driver to see the area immediately in front of a stopped bus to be sure there are no children there before moving the bus." This letter then explains: "The agency used the word 'view' in its ordinary, dictionar y sense to mean within the range of sight. Thus, most, but not literally all, of the front bumper must be visible to the driver by use of the crossview mirror to ensure that he or she can see children standing in front of the bus." This is still an accu rate expression of the agency's interpretation of the purpose of a crossview mirror and this phrase.

In your telephone conversation, you also expressed concern about the "legal effect" of Standard No. 111. You should be aware of @ 108 (a)(1)(A) of the Safety Act which states that

No person shall manufacturer for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard except as provided in subsection (b) of this section.

I hope this information is useful. If you have any additional questions, or need further information on this subject, please feel free to contact Mr. Shaw at this address or by telephone at (202) 366-2992.

ENCLOSURE

ID: nht88-3.28

TYPE: INTERPRETATION-NHTSA

DATE: 08/30/88

FROM: ERNIE J. BUNNELL -- PACIFIC T-TOPS INC.

TO: TAYLOR VINSON -- LEGAL COUNCIL US DEPT. OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/03/88 FROM ERIKA Z JONES TO ERNIE J. BUNNELL; REDBOOK A32, STANDARD 108

TEXT: Dear Taylor,

I was refered to you by the Department of Transportation regarding FMVSS #108 and the following:

The Department of Transportation guidelines for aftermarket and OEM rear spoilers which when mounted on the deck lid of a car obstruct the high mounted stoplamp.

Enclosed you will see (2) versions of rear spoilers (A) and (B):

A) It is designed to be at or below the rear brake light using the 5 degrees measurement as a guide.

B) It is designed to go over the horizontal intensity of the light.

We have been advised that the attachment does not need to comply with the ruling. However, we would like to know what the requirements are so that we can comply if possible.

If you need any additional information regarding this, please contact me. I shall look forward to hearing from you.

ID: nht88-3.29

TYPE: INTERPRETATION-NHTSA

DATE: 08/30/88

FROM: SPENCER A. DORBY -- SATE-LITE MFG. CO.

TO: JOAN TILGHMAN - NHTSA

TITLE: 2166

ATTACHMT: ATTACHED TO LETTER DATED 11/07/88 FROM ERIKA Z JONES TO SPENCER A DARBY, REDBOOK A32, STANDARD 125; LETTER DATED 05/19/88 FROM SPENCER A DARBY TO JOAN TILGHMAN RE REQUEST FOR INTERPRETATION OF FMVSS 1255, OCC-2166

TEXT: Dear Ms. Tilgham:

Attached is the drawing we referred to this AM on the phone, showing the recommended diagrams to help insure that Warning Device user will know how to erect the Emergency Warning Triangle properly.

As Chairman of the SAE Reflex Devices Subcommittee, I will be including these diagrams (or similar versions) in an updated version of SAE 774, a Recommended Practice document of the Society of Automotive Engineers, in the next approval process due thi s year.

Please call if I can be of any further assistance.

ON ANY TYPE HIGHWAY VEHICLE USING 1 TRIANGLE

Figure 3.

ON A NON-DIVIDED HIGHWAY TRUCK USING 3 TRIANGLES

Figure 4.

ON A DIVIDED HIGHWAY TRUCK USING 3 TRIANGLES

Figure 5.

RECOMMENDED DIAGRAMS TO BE "PERMANENTLY AND LEGIBLY MARKED" ON THE WARNING DEVICE, AND ALSO ON THE "OPAQUE PROTECTIVE REUSABLE CONTAINER".

Sate-lite MFG. CO.

CAD TITLE

125 DIAGRAMS

TRIA-DIA

Drawing Number 880830

ID: nht88-3.3

TYPE: INTERPRETATION-NHTSA

DATE: 08/11/88

FROM: JOSEPH F. MIKOLL -- VICE PRESIDENT TRANSPORTATION EQUIPMENT CORP

TO: ERICA JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/10/89 FROM ERIKA Z. JONES -- NHTSA TO JOSEPH F. MIKOLL, REDBOOK A33, STANDARD 217, 222 AND 302; LETTER DATED 11/15/88 FROM JOSEPH F. MIKOLL TO ERIKA Z. JONES -- NHTSA; OCC 2812; LETTER DATED 11/03/88 FROM ERIKA Z. JO NES -- NHTSA TO JOSEPH F. MIKOLL

TEXT: Dear Ms. Jones:

We are writing to you to confirm our understanding that our "Impact Control System", or safety bar is not in conflict with any existing standard for installation in school buses. The device was presented to various staff peopled in NHTSA on July 28, 1988. Our principal contact was Dr. Carl Clark.

Transportation Equipment Corp. was formed in December 1987. The company has conducted extensive market research to determine the concerns of the numerous interest groups who would be affected by installation of our system. The engineering and design process undertaken has resulted in solving two major problems involving the safe transportation of school bus passengers; 1) a drastic reduction of HIC (Head Injury Criteria) numbers by spreading the load across the chest, and 2) overcoming the utility problems associated with seat belt use on school buses.

Included for your review and evaluation are the following materials:

Engineers drawings and photographs of the device.

Video tape and written documentation of the dynamic testing conducted at the University of Michigan Transportation Research Institute.

Independent Consultants opinion on the design and dynamic test results.

Background information on our Consulting Engineers.

We have identified those vehicles under 10,000 pounds (small buses & mini vans) as a target market for installation of our system. At present, these vehicles are under a federal mandate to be equipped with seat belts. It is our objective to have our device offered as an alternative option to seat belts in this class of vehicle. We respectfully request your opinion concerning a ruling and/or confirmation of the systems acceptance as an alternative option.

If we have omitted any information needed to consider this matter, please do not hesitate to contact us.

We look forward to hearing from you at your earliest convenience.

ID: nht88-3.30

TYPE: INTERPRETATION-NHTSA

DATE: SEPTEMBER 1, 1988

FROM: W. E. BALDWIN PRESIDENT, K-R INDUSTRIES

TO: ERIKA Z. JONES -- CHIEF COUNCIL, NHTSA

ATTACHMT: MEMO DATED 11-03-88, TO W. E. BALDWIN, FROM ERIKA Z. JONES, STD. 108

TEXT: This is a follow-up of a letter sent you on August 3, 1988 which you forwarded to Mr. Finkelstein of NHTSA.

As we interpret Standard S4.1, our product meets all of the requirements except, possibly, S4.5.11(e), requiring that "all other lamps shall be wired to be steady burning. Our improvement consists of a lamp containing 5 bulbs, where each bulb is illu minated in sequential order. The time between each lamp illumination is less than 250ms, providing a steady photometric value, meeting S4.1.1.41(c). The red lens of the lamp is steadily illuminated, with the illusinated area moveing in a back and forth motion.

We feel that, since NHTSA has already tested and validated the use of a high mounted break lamp, any additional testing that would be conducted would only determine any improvement in fatal accident statistics. We are not questioning the necessity of the high mounted break lamp. We are offering what we think is a improvement on the lamp, without disturbing present NHTSA standards. In order for for us to determine if it would necessitate petitioning for a Rule change, a Administration interpretatio n of S4.5.11(e) is requested. Simply put, would Rule S4.5.11(e) cover a steadily illuminated light source that moves?

Thank you for your interest in this matter. I remain

ID: nht88-3.31

TYPE: INTERPRETATION-NHTSA

DATE: 09/02/88

FROM: ERIKA Z. JONES -- NHTSA

TO: GERALD PETERSON -- TARACO ENTERPRISES INC.

TITLE: NONE

ATTACHMT: LETTER DATED 05/17/88 FROM GERALD PETERSON TO ERIKA JONES; OCC - 2052; LETTER DATED 08/28/87 FROM CARL C CLARK TO JERRY PETERSON; LETTER DATED 09/29/86 FROM DALE T FANZO TO DIANE STEED

TEXT: Dear Mr. Peterson:

This responds to your May 17, 1988 letter to me asking for "information on petitions filed, concerning the safety problems on trucks." You also enclosed for the agency's information materials on the product you manufacture called a "Truk-Hedrest." Accord ing to the brochures you sent, the Truk-Hedrest attaches to the rear window of a vehicle by means of velcro and "is designed to help protect the head of the driver and passenger of a truck or van in an accident when their head is snapped back against the rear window or bulkhead of a vehicle." You also enclosed a copy of an August 28, 1987 letter which Mr. Carl Clark of this agency sent you regarding your product. The latter part of this letter addresses statements in your brochures relating to our regu lations and the Truk-Hedrest.

The National Highway Traffic Safety Administration (NHTSA) shares your concern for light truck safety and is currently reviewing a number of actions intended to improve the protection for occupants of such vehicles. This review has been described in det ail in the enclosed reports to Congress issued by NHTSA in May 1987 ("Light Truck and Van Safety") and April 1988 ("Safety Programs for Light Trucks and Multipurpose Passenger Vehicles"). Among the rulemaking activities considered by NHTSA for light tru cks is a possible extension of Safety Standard No. 202, Head Restraints, to those vehicles. The agency is presently reviewing petitions for rulemaking on this subject from Mr. Dale T. Fanzo of Bethel Park, Pennsylvania and Mr. Mark E. Goodson of Lewisvi lle, Texas. I have enclosed copies of these petitions for your information.

With regard to the brochures and materials you sent on your product, I would like to first to make it clear that Mr. Clark's letter on the Truk-Hedrest only expressed his personal opinions and interests concerning your product. His letter does not repre sent any official agency position regarding light truck safety in general or regarding your product in particular. Mr. Clark's letter was neither an approval nor

endorsement of your product by this agency. NHTSA does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. In addition, the agency cannot as a matter of law and will not as a matter of policy determine t he extent, if any, of the occupant protection provided by any commercial product apart from the context of an actual enforcement proceeding. Thus, the agency does not concur in any manner with Mr. Clark's assessement that the Truk-Hedrest "does indeed pr ovide excellent head protection" or with any other statement as to the effectiveness of your product.

Second, your brochures imply that the Truk-Hedrest has been shown to help protect against possible neck and head injuries when tested to "NHTSA guidelines." NHTSA has neither adopted or even developed guidelines for testing the Truk-Hedrest. Again, in h is letter to you Mr. Clark provided only his personal opinion on certain aspects of your product testing program. He expressed no agency recommendations or "guidelines" for testing a product such as yours "for rear end collisions up to 50 MPH," or with bowling balls, since no such guidelines exist.

My final clarification concerns the statements in your brochures that the Truk-Hedrest "Passes MVSS-302 Test for fire and toxic fumes." Please note that Standard No. 302, Flammability of Interior Materials, addresses only the flammability resistance of v ehicle components and not the toxicity of gases from burning materials.

With respect to your statment about meeting the FMVSS 302 requirement regarding fire, please note that if the Truk-Hedrest did not in fact meet those requirements and were installed in a vehicle by a motor vehicle manufacturer, distributor, dealer or rep air business, there could be a violation of the National Traffic and Motor Vehicle Safety Act. Section 108 (a)(2)(A) of the Act prohibits those persons from rendering inoperative any device or element of design installed pursuant to the Federal motor ve hicle safety standards. Installation of rapidly burning materials could vitiate the compliance of the materials which were present in the vehicle at the time of its sale to the first consumer and were certified as meeting FMVSS 302.

To repeat, in his letter to you Mr. Clark was only expressing his personal opinions and interests concerning your product and made no statements that should be construed as official agency positions. NHTSA does not endorse the Truk-Hedrest nor do we mak e any determination on the extent, if any, of the occupant protection provided by your product. I regret any confusion that may have resulted from Mr. Clark's letter to you on the Truk-Hedrest.

Please contact my office if you have further questions.

ENCLOSURES

ID: nht88-3.32

TYPE: INTERPRETATION-NHTSA

DATE: 09/02/88

FROM: R. YAMAUCHI -- NIPPON SEIKO K K

TO: NHTSA OFFICE OF VEHICLE SAFETY COMPLIANCE ENFORCEMENT

TITLE: DUAL MODE RETRACTOR (ELR MODE AND ALR MODE RETRACTOR)

ATTACHMT: ATTACHED TO LETTER DATED 06/19/88 FROM STEPHEN P. WOOD -- NHTSA TO R. YAMAUCHI; REDBOOK A33; INTERP 209

TEXT: The above retractor is an ELR which can change to ALR mode in order to fasten child seat.

Seat belt webbing of the dual mode retractor is pulled out to 100% extension position, where ELR mode changes to ALR mode. The ALR mode returns to ELR mode after specified amount of webbing is retracted. In ordinary use, that is webbing is not pulled o ut completely, ELR mode does not change and webbing moves smoothly without locking due to ALR mode.

We believe this dual mode retractor should be treated as ELR because ALR mode is voluntary act. Dual mode retractor, therefore, has to meet ELR performance requirement, and does not have to meet ALR performance requirement.

FMVSS 209 paragraph S5.2(k) specifies as follows. "---- An emergency locking retractor or a nonlocking retractor attached to upper torso restraint shall be subjected to 45,000 additional cycles of webbing withdrawal and retraction between 50 and 100 per cent extension. ----" If the dual mose retractor may be treated as ELR, the above testing will be applied. However, there is a problem. After webbing is fully pulled out, webbing locks at the above 50% extension position due to ALR mode. (In this case, the mode does not change to ELR unless much more amount of webbing is retracted.) To stop the webbing withdrawal just before the fully pulled out position might be able to prevent the change to ALR mode. But it will be in vain because 9 Kg load at that position will extend the webbing to the 100% extended position.

Retractor durability testing of the dual mode retractor can be conducted between 100% extended position and any ELR mode position, where more than specified amount has been retracted. As a test for this retractor, we request cycles of webbing withdrawal and retraction between 0 and 100% extension. We think this test cause no problem because requirement of S5.2(k) is less strict than that of this cycle test.

Please answer the following questions.

Q1 - Is dual mode retractor regarded as ELR? If so, is only the ELR requirement required?

Q2 - We requested 45,000 cycle test after dust should be conducted between 0 and 100% extension length. Is this correct? If not, how do we test the retractor.

We would appreciate if you would answer our questions.

Very truly yours,

ID: nht88-3.33

TYPE: INTERPRETATION-NHTSA

DATE: 09/06/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: ROBERT DAUGHERTY -- QUALITY ASSURANCE MANAGER SAFETY REHAB SYSTEMS, INC.

ATTACHMT: LETTER DATED 10/16/86 TO TERRY WOODMAN FROM ERIKA Z. JONES; LETTER DATED 07/31/87 TO RICHARD J. MAHER FROM ERIKA Z. JONES; LETTER DATED 02/05/88 TO ERIKA Z JONES FROM ROBERT DAUGHERTY, OCC - 1588; UNDATED BROCHURE SAFETY PLUS MODEL 501 STROLLER ;

TEXT: Dear Mr. Daugherty:

This is a response to your letter of February 5, 1988, in which you sought an interpretation of Standard 213, Child Restraint Systems (49 CFR @ 571.213). I regret the delay in this response. Specifically, your letter stated that your company manufactur es wheelchairs for severely handicapped children. Your letter stated that your company believes that Standard 213 does not apply to "durable medical products (wheelchairs, positioning systems)" and asked if this belief is correct. As explained below, y our belief is not entirely correct.

Section S3 of Standard No. 213 specifies that "this standard applies to child restraint systems for use in motor vehicles and aircraft." Section S4 of the standard defines a child restraint system as "any device except Type I or Type II seat belts, desig ned for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 50 pounds or less." No exception is made for restraints designed for use by physically handicapped children who weigh 50 pounds or less. Further, paragraph S6.1 .2.1.1 of Standard No. 213 includes the following language: "A child harness, booster seat with a top anchorage strap, or a restraint designed for use by physically handicapped children shall be installed at the center seating position of the standard se at assembly in accordance with the manufacturer's instructions provided with the system pursuant to S5.6." This language makes clear that restraints designed for use by physically handicapped children are subject to the requirements of Standard No. 213.

Under these criteria, wheelchairs, strollers, and so forth would not be "child restraint systems" within the meaning of Standard No. 213 because these devices are designed to transport children outside of a motor vehicle or aircraft. Therefore, wheelchai rs, strollers, and similar devices are not child restraint system within the meaning of S3 of Standard No. 213. Such devices may be subject to regulation by the Food and Drug Administration, under its authority to regulate medical "devices."

However, the devices described in your letter as "positioning systems" are child restraint systems subject to the requirements of Standard No. 213. Your "Safety Plus Model 501" includes a "removable positioning unit" that is designed to restrain and po sition a child riding in a motor vehicle. Your "900 Series Transporter" is designed so that the rear wheels can be folded under it to allow it to be used to restrain and position a child riding in a motor vehicle. Therefore, these devices are "child res traint systems" within the meaning of S3 of Standard No. 213, and must be certified as complying with the requirements of the standard. NHSTA has said in the past that, since it is possible to offer handicapped children the same level of crash protectio n afforded to all other children, there is no reason to permit handicapped children to be (See the enclosed October 16, 1986 letter I sent to Mr. Terry Woodman on this subject.)

You also asked if there are any standards applicable to "tie-downs" used on school buses. These "tie-downs" are straps designed to restrain wheelchairs and their occupants in a motor vehicle in the event of a crash. Since wheelchairs are not subject to Standard No. 213 or any other of this agency's regulations, as explained above, we have no standard applicable to "tie-downs" or other devices used to position wheelchairs in motor vehicles. I explained this in detail in the enclosed July 31, 1987 lett er to Mr. Richard Maher.

I hope this information is helpful. If you have further questions or need more information on this subject, please feel free to contact Ms. Joan Tilghman of my staff at this address or by telephone at (202) 366-2992.

ENCLOSURES

Sincerely,