Interpretation ID: nht73-5.22

DATE: 09/19/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: International Bicycle Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 21, 1973, to Dr. Gregory concerning your wish to import and sell an "electric moped".

Although you did not enclose a pamphlet on the Electra, we are familiar with the conventionally powered mopeds. Two-wheeled powered vehicles are "motorcycles" for purposes of the Federal motor vehicle safety standards and must comply with standards applicable to that category. In addition to Standard No. 108, standards applicable to motorcycle controls (No. 122) and brake systems (No. 123) became effective January 1, 1974 and September 1, 1974, respectively. The standards are found in Table 49 Code of Federal Regulations Part 571.

The manufacturer of the vehicle, or the importer as a statutory manufacturer, certifies on the basis of his own tests or other engineering information that the vehicle meets all applicable Federal standards at the time of its manufacture. The regulation for this requirement is Part 567 of Title 49. It is a self-certification procedure, subject to penalties for noncompliance, and no "approval" is obtained from this agency.

Part 555 of Title 49 Sets forth the procedures for applying for temporary exemption from any standard on one of four grounds. Of interest to you will be the exemption procedure for hardship and facilitation of development of low-emission vehicles.

I enclosed an information sheet telling you where you may obtain these materials.

ENC.

International Bicycle Corporation

August 21, 1973

Dr. James Gregory Administrator National Highway Traffic Safety Administration

We are enclosing a pamphlet on an electric moped sold on the East Coast as the Solo Electra, and intended to be sold on the West Coast as the International Electra. The units will be identical.

With the help of the California Motor Vehicles Department, we licensed our demonstrator model, only to find out later from the Highway Patrol that more requirements must be met.

We now understand that we must obtain certification that the Electra meets Federal Motor Vehicle Safety Standards, and also that it must conform to Federal Standard 108. We need to know what is involved in obtaining this certification. In addition, we were informed that the lights must be on the California approved list, which is a minor problem we can look after without difficulty.

In our opinion, an inexpensive electrically powered commuter vehicle replacing some use of automobiles is very desirable from many points of view. However, we do not feel that it will become a volume item for some time, and doubt that 1000 annually will be sold for the next few years. Therefore, while we would like to import and sell these Electras, we are not in a position to go to a great deal of expense in meeting standards which Honda, and other major manufacturers can handle without difficulty.

We would appreciate knowing what must be done so that we can weigh the costs against sales potential, and drop this project if it appears to be too difficult or too expensive.

A. E. Davies Vice President