ID: nht91-4.48

DATE: July 12, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA; Signature by Ken Weinstein)

TO: Samuel Albury -- President, Three Wolves and Associates, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 6-3-91 from Samuel Albury to Chief Counsel, NHTSA (OCC 6112)

TEXT:

This responds to your letter of June 3, 1991 concerning whether your company would be considered the manufacturer of certain vehicles. Your company is planning to use jeep conversion kits on Chrysler Corporation jeeps. Under one approach, your company would purchase the basic stripped down model jeep from Chrysler and add the body, stereo, air conditioning, tires, running lights, carpeting, and high visibility seats. You state that the body would be one solid piece and that your company would add wheel wells, doors, a solid or canvas top, and a windshield. Alternatively, your company would purchase the chassis, with engine and transmission, from Chrysler and add the above items.

I am pleased to have this opportunity to explain our regulations to you. Some background information on Federal motor vehicle safety laws and regulations may be helpful. As you are aware, the National Highway Traffic Safety Administration (NHTSA) is authorized, under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1381 et seq., the Safety Act), to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA, however does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. I will address the responsibilities of your company under the Safety Act in each of the situations you described. First, if your company purchased a stripped down vehicle from Chrysler and made the modifications described, it could be considered an alterer under our regulations. Under 49 CFR Part 567, Certification, an alterer is defined as:

A person who alters a vehicle that has previously been certified . . . other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, . . . before the first purchase of the vehicle in good faith for purposes other than resale . . . .

As an alterer, your company would be required to certify compliance of its vehicles with the Federal Motor Vehicle Safety Standards in accordance with 49 CFR Part 567. The only exception would be if:

1. The modifications consisted solely of "readily attachable components;" or

2. The modifications were only "minor finishing operations."

Whether modifications involve "readily attachable" components depends on the difficulty in attaching those components. In the past, the agency has looked at such factors as the intricacy of installation and the need for special expertise. Without extraordinary ease of installation, NHTSA would not consider modifications involving the addition or substitution of seats to involve "readily attachable" components.

If considered an alterer, your company would be subject to the certification requirements of 49 CFR S567.7. These requirements include provisions that the alterer supplement the existing manufacturer certification label, which must remain on the vehicle, by affixing an additional label. The label would state that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards. The label would also state the alterer and the month and the year in which the alterations were completed.

In addition to these certification requirements, an alterer is considered a "manufacturer" for the purposes of the Safety Act. Among other things, this means an alterer is responsible for notification and remedy of defects related to motor vehicle safety and noncompliances with applicable Federal motor vehicle safety standards, as specified in sections 151-160 of the Safety Act. Alterers also are subject to the requirements of 49 CFR Part 573, Defect and Noncompliance Reports.

Second, as an alternative, your company is considering buying a chassis from Chrysler. In that case, your company would likely be considered a final-stage manufacturer. Under 49 CFR Part 568, Vehicles Manufactured in Two or More Stages, a final-stage manufacturer is defined as:

A person who performs such manufacturing operations on an incomplete vehicle that it becomes a completed vehicle.

Under the regulation, incomplete vehicle is defined as

An assemblage consisting, as a minimum, of frame and chassis structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed vehicle.

As a final-stage manufacturer, your company's certification responsibilities would depend on the information provided by the manufacturer of the incomplete vehicle. Under 49 CFR Part 568, the incomplete vehicle manufacturer must furnish your company with a document which states one of the following three things concerning the incomplete vehicle:

1. The vehicle when completed will conform to some or all of the applicable safety standards if no alterations are made to any identified components of the incomplete vehicle;

2. The vehicle when completed will conform to some or all of the applicable safety standards if specific conditions are followed by the final-stage manufacturer;

3. Conformity with some or all of the applicable safety standards is not substantially affected by the design of the incomplete vehicle, so the incomplete vehicle manufacturer makes no representation as to conformity with the standards.

After receiving this document from the incomplete vehicle manufacturer, your company would be required to certify compliance with the safety standards. In addition to these certification requirements, a final-stage manufacturer is considered a "manufacturer" for the purposes of the Safety Act. Among other things, this means a final-stage manufacturer is responsible for notification and remedy of defects related to motor vehicle safety and noncompliances with applicable Federal motor vehicle safety standards, as specified in sections 151-160 of the Safety Act. In addition, final-stage manufacturers are subject to the requirements of 49 CFR Part 573, Defect and Noncompliance Reports.

I am also enclosing a general information sheet for manufacturers of new vehicles. This sheet highlights the relevant Federal statutes and regulations and explains how to obtain copies of the regulations.

I hope that this information is useful. If you have any further questions, please contact John Rigby at 202-366-2992.

ID: nht91-4.49

DATE: July 12, 1991

FROM: Garth C. Bates, Jr. -- Vice President, Stewart & Stevenson Services, Inc.

TO: Paul J. Rice -- Chief Counsel, NHTSA

COPYEE: B. Felrice; F. Grubbe; D. Bates; L. Austin

TITLE: None

ATTACHMT: Attached to letter dated 7-30-91 from Paul Jackson Rice to Garth C. Bates, Jr. (A38; Std. 301)

TEXT:

Recent discussions with Mr. Barry Felrice and Mr. Fred Grubbe at NHTSA have been very helpful in the planning phase of our carbon fiber, CNG automotive fuel tank program.

As previously discussed, we believe that high quality, carbon fiber tanks are an economical alternative to the present steel/aluminum tanks. Their use will speed the utilization of CNG automotive fuels without compromising safety in any fashion.

It is our understanding that currently there exist no DOT/NHTSA regulations governing the construction or testing of such tanks. For business purposes, we would like to request a letter from NHTSA confirming the above. Mr. Felrice advises us that you are the appropriate source of such a document, and we would very much appreciate your assistance.

ID: nht91-4.5

DATE: May 23, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA; (Signature by S. Wood)

TO: Bill Lewandoski (Lewandowski) -- Account Manager, Kelsey Products Division

TITLE: None

ATTACHMT: Attached to letter dated 4-30-91 from Bill Lewandowski to Taylor Vinson; Also attached to letter dated 11-22-91 from Paul Jackson Rice to William J. Lewandoski (A38; Std. 108); Also attached to letter dated 7-9-91 from William J. Lewandowski to Robert Helluth (OCC 6245)

TEXT:

This responds to your letter of April 30, 1991, to Taylor Vinson of this Office with respect to the regulation of trailer stop lamp activation by Standard No. 108.

You have enclosed a photocopy of literature on the Tekonsha Voyager electronic brake control. This system incorporates a manual override side bar that manually activates the trailer brakes without a corresponding activation of the trailer stop lamps. The reason for this is the manufacturer's view that "STOPPING IS NOT THE INTENT. BY NOT DRIVING THE STOPLIGHTS DURING MANUAL ACTIVATION, THE VOYAGER ELIMINATES FALSE BRAKE LIGHT SIGNALS . . . ." The literature carries the notation that "THE VOYAGER AND VOYAGER XP MEET NATIONAL HIGHWAY TRANSPORTATION (sic) SAFETY ADMINISTRATION (N.H.T.S.A.) REGULATIONS REGARDING TOW VEHICLE/TRAILER LIGHT APPLICATION." You have asked whether Standard No. 108 permits application of the trailer brakes without activation of the towing vehicle/trailer stop lamps.

It does not. Tekonsha misunderstands the function of a stop lamp. A stop lamp not only indicates the intent of the driver to stop, but also the intent of the driver "to diminish speed by braking." (see the definition of "stop lamp" in SAE Standard J568c, Stop Lamps, August 1970, incorporated by reference in Standard No.108). Paragraph S5.5.4 of Standard No. 108 requires that "The stop lamps on each vehicle shall be activated upon application of the service brakes." The Voyager electronic control applies the service brakes to diminish vehicle speed, and therefore the stop lamps are required to be activated.

The installation of the Voyager by a manufacturer or dealer before the initial sale of a trailer would therefore appear to be a violation of Standard No. 108 since its operation would create a noncompliance with the standard. As an aftermarket device, it is subject to the "render inoperative" prohibition of 15 U.S.C. 1397(a)(2)(A). Any manufacturer, distributor, dealer or motor vehicle repair business installing the device after the trailer's initial sale is, in effect, rendering the trailer's stop lamps inoperative when the device is used. Civil penalties are provided for with respect to violations of either Standard No. 108, or section 1397(a)(2)(A). The statement as to compliance with NHTSA regulations is wrong.

We appreciate your bringing this matter to our attention. I am forwarding a copy of your letter to our Office of Vehicle Safety Compliance for such further action as it deems appropriate.

ID: nht91-4.50

DATE: July 16, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Allen I. Swenson -- The Compliance Group, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 5-23-91 from Allen I. Swenson to Robert F. Helmuth (OCC 6085)

TEXT:

This responds to your letter to Robert Hellmuth, the Director of NHTSA's Office of Vehicle Safety Compliance, seeking information about a recent amendment requiring lap/shoulder belts to be installed at rear outboard seating positions in light trucks and multipurpose passenger vehicles. You were particularly interested in the requirements for readily removable seats at such positions. I am pleased to have this opportunity to explain our regulation to you.

As you correctly noted, NHTSA published a final rule on July 30, 1990 (55 FR 30914), addressing requirements for lap/shoulder belts to be installed in all forward-facing rear outboard seating positions in light trucks and multipurpose passenger vehicles. That July 30 final rule specifically addressed the issue of lap/shoulder belts at readily removable seats (that is, seats designed to be easily removed and replaced by means installed by the manufacturer for that purpose). In response to a petition by Ford, the agency included the following discussion in the preamble to the July 30 rule (see 55 FR 30914, at 30916-30917):

. . . These vehicles do not currently use, nor did Ford plan to begin using, a release mechanism that complies with the requirements that are scheduled to take effect on September 1, 1991, Accordingly, Ford will need to make the changes described in its petition. NHTSA has concluded that an additional year of leadtime is needed to allow Ford to make the necessary changes. Therefore, this notice delays the requirement for rear seat lap/shoulder belts to be installed at outboard seating positions on readily removable seats for one year, so that it now applies to vehicles manufactured on or after September 1, 1992.

Hence, outboard seating positions on readily removable seats in light trucks and multipurpose passenger vehicles are not required to be equipped with lap/shoulder belts until September 1, 1992. Before that date, those seating positions may be equipped with either lap-only belts or with lap/shoulder belts, at the manufacturer's option.

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

ID: nht91-4.51

DATE: July 16, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA; Signature by Kenneth Weinstein)

TO: Gerald Farr -- P. Eng., Senior Compliance Engineer, Compliance Engineering and Vehicle Testing, Road Safety and Motor Vehicle Regulation Directorate, Transport Canada (ASFAAA)

TITLE: None

ATTACHMT: Attached to letter dated 6-19-91 from Gerald Farr to Paul Jackson Rice (OCC 6172)

TEXT:

This responds to your letter of June 19, 1991, requesting information regarding the method used to calculate the angle specified in section S4.3.1.1 of Standard No. 210.

Your first question asks whether the agency uses a three dimensional protocol or a two dimensional protocol when calculating the angle formed by the line from the seating reference point to the nearest contact point of the belt with the hardware attaching it to the anchorage. NHTSA uses a two dimensional protocol for these purposes. The agency recognizes that, as stated in your letter, this does not take into account the transverse coordinate of these two points. However, the agency does not believe that use of a two dimensional protocol diminishes the safety benefits offered by the safety belt system.

Your second question asks whether the agency has made any interpretations of the phrase "the nearest contact point of the belt with the hardware connecting it to the anchorage." The agency has never made a generally applicable interpretation of this phrase. When manufacturers have requested an interpretation for a specific design, the agency has indicated which point we would consider "the nearest contact point." If you have a specific design that concerns you, we can make a similar interpretation if you send us a diagram.

It is always a pleasure to hear from representatives of Transport Canada. We believe our cooperation has been mutually beneficial for many years. If you have further questions or need some additional information in this area, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992.

ID: nht91-4.6

DATE: May 28, 1991

FROM: Roddy Williams -- Container Enterprise

TO: Paul J. Rice -- Chief Counsel, NHTSA

TITLE: Reference: FMVSS No. 115 Vehicle Identification

ATTACHMT: Attached to letter dated 7-12-91 from Paul Jackson Rice to Roddy Williams (A38; Std. 115; Part 571.7(f); VSA 108(a)(2)(A))

TEXT:

Container Enterprise is a chassis manufacturer in New Orleans, La. and is registered with S.A.E. to apply VIN numbers. We are presently converting container chassis from their original 23' length to a new length of 27' which will enable them to conform to the new Federal Bridge Formula.

Leasing companies have contracted us to modify these older chassis carrying a five digit VIN number. According to S.A.E., current regulations require a seventeen digit VIN number on any new and remanufactured productions. Any length change would also constitute a VIN number change.

Explanation of Modification:

The original chassis is 23' long. We remove the axles and half of the cross members on the original frame. We manufacture a 12' subframe and reinstall axles to the subframe. The subframe upon completion will extend the chassis length to 27'. The conversion will allow the chassis to slide open or closed.

Upon completion of modification, Container Enterprise will issue a new manufacturer plate with a new VIN number and date of remanufacture. A remanufacture certificate of orgin is sent to the leasing company and the leasing company registers the chassis.

It is our understanding after a telephone conversation with D. Nacoma with N.H.T.S.A. that the original manufacturer is no longer responsible after remanufacturing is completed. It is also our understanding that the remanufacturer assumes responsibility of the chassis meeting all of N.H.T.S.A. standards.

According to the Department of the Treasury Publication 510, Excise Taxes, Page 10, Heavy Trucks, Trailers, & Tractor: F.E.T. is not taxable on remanufactured equipment.

We feel that these procedures comply with all requirements and regulations. We would appreciate your review of these procedures and responding with any comments or opinions.

Should you require additional information or clarification, please contact me at your convenience.

ID: nht91-4.7

DATE: May 29, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Vel McCaslin -- Program Director, Grace After School

TITLE: None

ATTACHMT: Attached to letter dated 4-1-91 from Vel McCaslin to NHTSA, Office of Vehicle Safety Standards (OCC 5924)

TEXT:

This responds to your letter of April 1, 1991 requesting clarification of the National Traffic and Motor Vehicle Safety Act (the Act) and Federal regulations at 49 CFR Part 571 as they apply to 15 passenger vans used to transport students from Houston Independent Schools to an After School Program at your church.

I am pleased to have this opportunity to clarify the operation of Federal law as it applies to school buses. The National Highway Traffic Safety Administration (NHTSA) has used its authority under the Act to issue motor vehicle safety standards that apply to the manufacture and sale of various types of new motor vehicles. One type is the school bus. NHTSA defines "school bus" as a motor vehicle designed for carrying 11 or more persons, including a driver, and sold for purposes that include transporting students to and from "school or school-related events." Therefore, unless your program would be considered a "school or school-related event," your vehicles would not be considered "school buses" under Federal law. In order for NHTSA to determine if your program would be considered a "school or school-related event," you would need to provide us with further information about your program.

Under Federal law, the answer to the question of whether your buses are school buses bears on the legal obligations of the seller, but not those of the purchaser or user, of new school buses. It is a violation of Federal law for any person to SELL any new vehicle that does not comply with all Federal school bus safety standards if that person is aware that the purchaser intends to use the vehicle as a school bus. However, it is not a violation of Federal law for the purchaser to BUY or USE a vehicle to transport school children that does not comply with all the Federal standards.

Under State, and common law, whether your buses complied with the Federal standards may have legal significance for you as a vehicle user. Since the individual States have authority over the USE of vehicles, you must look to Texas law to determine if your After School Program may use non- complying vans to transport school children. In addition, using non- complying vans as a school bus could result in increased liability in the event of an accident. You might want to consult your attorney and insurance company to discuss this matter.

I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992.

ID: nht91-4.8

DATE: May 29, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: James E. Rooks, Jr. -- Staff Attorney, Association of Trial Lawyers of America

TITLE: None

ATTACHMT: Attached to letter dated 3-27-91 from James E. Rooks, Jr. to Paul J. Rice (OCC 5876)

TEXT:

This responds to your letter of March 27, 1991 concerning the applicability of various motor vehicle safety standards to the repair or replacement of damaged motor vehicle windshields. You enclosed a copy of the "Legal Advisory" column from the November 1986 issue of Glass magazine. That column stated that the National Highway Traffic Safety Administration ("NHTSA") advised the National Glass Association that "federal windshield safety standards are not applicable to replacement windshield installations once vehicles have left their new car dealers' lots." The column went on to state that "no kind or amount of work on a damaged windshield renders it inoperable in violation of federal law."

Your letter asked whether NHTSA currently adheres to the above position with regard to two Federal motor vehicle safety standards: Standard No. 212, Windshield Mounting, and Standard No. 216, Roof Crush Resistance. In a subsequent telephone conversation with John Rigby of this office, you asked the agency also to address the applicability of these principles to Standard No. 205, Glazing Materials.

I am pleased to have the opportunity to discuss these issues. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act of 1966 ("Act"), 15 U.S.C. 1397(a)(1)(A), provides that no person may manufacture for sale, sell, introduce into interstate commerce or import any motor vehicle or item of motor vehicle equipment that does not conform with all applicable Federal motor vehicle safety standards. However, pursuant to section 108(b)(1) of the Act, 15 U.S.C. 1397(b)(1), that prohibition does not apply "after the first purchase of (the vehicle or equipment) in good faith for purposes other than resale." On the other hand, section 108(a)(2) of the Act, 15 U.S.C. 1397(a)(2), provides that: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . . "

With respect to Standards 212 and 216, which impose requirements applicable to completed motor vehicles, a manufacturer is not required to assure that the vehicles it manufactures remain in compliance after they have been sold for purposes other than resale. Moreover, a repair business that replaced a windshield that was previously damaged could not violate the "render inoperative" provision of the Act, regardless of what sealant was used. As NHTSA stated in a September 3, 1981 letter to the National Glass Dealers Association, even if it were somehow determined that the repaired vehicle did not satisfy the requirements of Standard No.

212 or No. 216, there would be no violation of the "render inoperative" provision of the Act. This is because the object or event that damaged the windshield in the first place had already rendered the windshield "inoperative" with respect to these standards. See also an October 5, 1983 letter to Anthony M. Peterson of Lansing Auto Glass Company. However, if for some reason a repair business were to replace a windshield that was not previously damaged, it could be held liable under section 108(a)(2) if it knew that its action caused the vehicle to no longer comply with either standard.

I would also like to deal with a relatively unlikely scenario. If a windshield needs to be repaired or replaced prior to the first sale to a consumer (e.g., due to breakage while en route from the manufacturer's factory to the dealer's showroom), the seller is required by section 108(a)(1)(A) to assure that the vehicle is brought into compliance with all applicable standards.

The situation is somewhat different with respect to Standard No. 205, which establishes, inter alia, strength and light transmittance performance requirements that must be met by glazing materials used in motor vehicles. Not only must the glazing in new vehicles meet this standard, replacement glass must also comply. Thus, any person who installs motor vehicle glazing that is not certified as being in compliance with Standard No. 205 would violate section 108(a)(1)(A), regardless of whether the vehicle is new. This would be because the installer would be selling or otherwise introducing into interstate commerce an item of motor vehicle equipment (i.e the glazing) that did not comply with an applicable safety standard. We have stated this interpretation in previous letters (most recently in our letter of March 14, 1991 to Loren Thompson).

Finally, you asked in your letter "whether these positions have yet been tested in court." We are not aware of any litigation in which any of the interpretation letters cited above have been considered.

I hope that this information is useful. If you have any further questions, please contact John Rigby of this office at 366-2992.

ID: nht91-4.9

DATE: May 29, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Richard H. Lucki -- U.S. Factory Representative, Peugeot, U.S. Technical Research Company

TITLE: None

TEXT:

This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect. You asked whether a planned gear position display for automatic vehicles would meet the standard's requirement that full gear position information be provided in a single location. As discussed below, the answer to that question is yes.

By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles and equipment meet applicable standards. The following represents our opinion based on the facts provided in you letter.

As you are aware, on March 26, 1991, this agency published in the Federal Register a final rule amending Standard No. 102. Among the amendments is a new S3.1.4.4 that requires, for all automatic transmission vehicles, that full gear position information, i.e., identification of shift level positions, including the position of the gears in relation to each other, and the gear position selected, be displayed "in view of the driver in a single location."

According to a drawing enclosed with your letter, your planned gear position display would be located on the instrument panel, between the speedometer and tachometer. The current gear position, either P, R, N, D, 3, 2, or 1, would be shown in a square, by means of electronic display. The position of the gears in relation to each other, i.e., P R N D 3 2 1, would be marked adjacent to the electronic display. You state that the gear positions in relation to each other will be illuminated when the headlamps are activated.

It is our opinion that your planned design would meet S3.1.4.4's requirement that full gear position information be displayed in a single location. The gear position selected would be shown in the square electronic display. The position of the gears in relation to each other would be marked adjacent to the electronic display. Because the marking of the position of the gears in relation to each other would be adjacent to the electronic display, it is our opinion that all of the information would be considered to be provided in a single location.

I note that this same issue was addressed in the preamble to the March 1991 final rule, in connection with a comment submitted by Chrysler. The agency stated the following: If Chrysler wishes to provide a display of current gear position information on the instrument panel, it is free to do so. Under the amendment, it can either provide full gear position information at that location, e.g., include a "P R N D L" label adjacent to the display, or it can provide a display of current gear position information only on the instrument panel and include a display of full gear position information elsewhere, e.g., on the floor console. 56 FR 12470, March 26, 1991.

Your proposed design is consistent with the first of the two options discussed in that paragraph.

I hope this responds satisfactorily to your concerns. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.

ID: nht91-5.1

DATE: July 16, 1991

FROM: Vel McCaslin -- Director, Grace After School

TO: Mary Versailles -- United States Department of Transportation

TITLE: None

ATTACHMT: Attached to letter dated 9-6-91 from Paul Jackson Rice to Vel McCaslin (A38; Part 571.3)

TEXT:

Please refer to the attached letter, last sentence in paragraph 2, from Paul Jackson Rice dated May 29, 1991.

In order for you all to determine if we would be considered a school or school-related event, let me explain what Grace After School does.

We operate under the auspicies of Grace Presbyterian Church from 3:00 p.m. until 6:00 p.m. daily. Our 3 vans (15 passenger) pick up children Kindergarten through 5th grade from three different area schools and bring them over to Grace Church. We provide snacks, have a period of about 1 hour for homework, and then go into acitivities like roller skating, art, music, and religion classes. We also have Ballet and Gymnastics here at the Church if they wish to participate. These children are from single parent families or working parents' children.

We do accept Grace School children into our program but they are already here at the Church and need no transportation.

I am enclosing one of my brochures for you to view. Please accept my many thanks for all your kind help in this manner.

Attachment

Grace After School Brochure. (Text and graphics omitted.)

Attachment

Letter dated 5-29-91 from Paul Jackson Rice to Vel McCaslin. (Text omitted.)