Interpretation ID: aiam2795
38 N. Main Street
Freeport
NY 11520;
Dear Mr. Shebar: This responds to your letter to Joan Claybrook on March 23, 1978, whic urges an extension of the exemption presently granted to TVR Cars of America, Ltd., from compliance with Standard No. 215, *Exterior Protection*. As noted in our earlier letter to TVR, Standard No. 215 was issued under the authority of one statute, the National Traffic and Motor Vehicle Safety Act, while the upcoming Part 581 *Bumper Standard* is issued under authority of this statute and a second one, the Motor Vehicle Information and Cost Savings Act (the Cost Savings Act).; Our earlier letter pointed out that the Cost Savings Act does no contain exemption authority which is as broad as that contained in the National Traffic and Motor Vehicle Safety Act. In the case of Part 581, the Department of Transportaiton (sic) can only exempt a passenger motor vehicle 'manufactured for a special use if (the) standard would unreasonably interfere with the special use of such vehicle' (15 U.S.C. S1912(c)(1)(B)). The legislative history of this provision cites a 4- wheel-drive vehicle equipped with a snow plow attachment as an example of a special use that would be unreasonably interfered with by a bumper standard.; Upon careful consideration of the issues raised in your letter, we d not believe there is an available basis for extension of TVR'd (sic) present exemption beyond the September 1, 1978, effective date of Part 581. The particular financial and engineering circumstances of TVR do not bear upon the limited grounds for exemption contained in the Cost Savings Act.; Thank you for bringing this matter to our attention. Sincerely, Joseph J. Levin, Jr., Chief Counsel