Interpretation ID: nht95-1.26

TYPE: INTERPRETATION-NHTSA

DATE: January 16, 1995

FROM: Ken Liebscher -- President/Director, Electric Car Company

TO: Administrator, NHTSA

TITLE: None

ATTACHMT: ATTACHED TO 2/13/95 LETTER FROM PHILIP R. RECHT TO KEN LIEBSCHER (A43; PART 555)

TEXT: The Electric Car Company Inc. is situated at 401 Lincoln St., Box 618, Everson WA 98247. It was incorporated in the State of Nevada.

This is a petition to be exempted from six Federal motor vehicle safety standards for passenger cars that we manufacture using electric power, the MI Series Electric Car. The basis of the petition is that compliance with the standards will cause substan tial economic hardship. The standards for which the exemptions are requested are:

1. Standard # 201, Occupant protection in interior impact. 2. Standard # 203, Impact protection for the driver from the steering control system. 3. Standard # 204, Steering control rearward displacement. 4. Standard # 208, Occupant crash protection. 5. Standard # 214, Side door strength. 6. Standard # 216, Roof crush resistance.

The MI-6 (pictured) is constructed from Dupont Kevlar composite fiberglass material and according to the manufacturer, is four times the strength as conventional fiberglass and we feel confident that it will conform to all applicable Federal motor vehicl e safety standards. However, thirty-mile per hour barrier crash testing is needed to determine the actual energy absorbing characteristics. All component parts of the MI-6 are Original Equipment Manufacturer products and, as such, in compliance of Nati onal Safety Standards. The restraint systems were also purchased from OEM and are installed as per standards.

We request an exemption of two years after which we expect to certify compliance with these standards. To require immediate compliance would create substantial economic hardship. I have enclosed the last audited year end financial statement as well as the last unaudited quarterly statement. The cost for "one set" of testing for the standards on one vehicle is approximately $ 30,000, exclusive of the costs of delivering the vehicle to the test facility. An exemption would permit vehicle sales and the generation of cash permitting testing while the exemptions are in effect. The Company expects to produce six vehicles for demonstration purposes and 100 limited edition vehicles in the first year. A denial of the petition would delay the Company's pro duction while we attempt to test for conformance, but the costs of testing would require a retail price of $ 50,000 for an MI-6. We doubt that we could sell a car at this price, and that, accordingly, we would be forced out of business in the year follo wing a denial of this petition.

Granting of the exemption would be in the public interest and consistent with the National Traffic and Motor Vehicle Safety act by helping to relieve environmental problems associated with automotive transportation. The Company believes that we can make a very positive contribution to the country's clean transportation needs quickly and effectively.

(FOLLOWING ATTACHMENTS OMITTED: 1. MI-6 ELECTRIC AUTOMOBILE SPECIFICATIONS AND TECHNICAL DATA; 2. E.T.C. INDUSTRIES QUARTERLY REPORT AND FINANCIAL STATEMENTS)