Interpretation ID: 12196.ZTV
Project Coordinator
Recreational Electric Vehicles Int. LLC
9330 Industrial Trace
Alpharetta, GA 30201
Dear Mr. Goodman:
We have received your petition of April 8, 1996, to the Administrator requesting a temporary exemption from several Federal motor vehicle safety standards. Your petition is incomplete, as Taylor Vinson explained when you phoned on April 29. I am enclosing a copy of the temporary exemption regulation (49 CFR part 555) so that my comments will be clearer.
First, every petition must contain arguments as to why an exemption is in the public interest and consistent with the objectives of traffic safety. This information is required by Sec. 555.5(b)(7) and is lacking from your petition.
You have petitioned on alternative bases, which is permissible, but the requirements for each basis differ. Applications for exemptions for low-emission vehicles must contain the information specified in Sec. 555.6(b), and those for equivalent overall level of safety must follow the requirements of Sec. 555.6(d). Although you have explained in sufficient detail the exemptions you require and why you require them, the safety arguments required by subsections (b) and (d) have not been made. We suggest that you submit a revised petition that treats each basis separately. If you have any questions on the petition, you may call Taylor again at 202-366-5263.
For planning purposes, manufacturers should expect a decision three to four months after filing a petition that meets our requirements. This time is needed, in part, to prepare, publish, and evaluate comments to a Federal Register notice which is part of each temporary exemption proceeding.
Sincerely,
Samuel J. Dubbin Chief Counsel
Enclosure ref:555 d:5/3/96