Interpretation ID: aiam5359
Engine Management Legislation and Certification Lotus Cars
Ltd. Hethel
Norwich
Norfolk NR14 8EZ England;
Dear Mr. Bloomfield: This responds to the letter from Ms. Rachel Jelly formerly of your company, concerning low volume CAFE exemptions. I apologize for the delay in our response. Ms. Jelly asked whether Bugatti Automobili S.p.A. (Bugatti) and Lotus Cars, Ltd. (Lotus), both of which are controlled by the same holding company, may submit separate low volume CAFE exemption petitions requesting two alternative standards. The answer to this question is no. Since any alternative CAFE standard would apply to Bugatti and Lotus together, a single combined petition must be submitted for a single alternative standard. The reasons for the above response are discussed in the attached letter from NHTSA to Mr. Lance Tunick, of Bugatti. Mr. Tunick's letter to NHTSA raised issues that are of concern to both Bugatti and Lotus. Thus, NHTSA's response to Mr. Tunick should address Lotus' concerns about filing for alternative CAFE standards. I hope this information is helpful. If there are any questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel;