Interpretation ID: nht91-7.52

DATE: December 20, 1991

FROM: James C. Hansen -- Product Development, Model E Concepts

TO: Office of the Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2/19/92 from Paul Jackson Rice to James Hansen (A39; Part 567)

TEXT:

In January 1992, we will begin an engineering study relating to a proposed alteration of a vehicle that has been previously certified in accordance with National Traffic and Motor Vehicle Safety Act of 1966 (Vehicle Safety Act, 15 U.S.C. 1381 et seq.).

More specifically, this proposed alteration would be conducted on new and used automobiles, vans, and pickups. The purpose of the alteration, is to convert these vehicles to a hybrid version of an electric powered highway vehicle, and to do so without infringing upon the safety provisions of the vehicle as it was originally manufactured. At the present time, our alteration plans include removal of the internal combustion engine and associated support components, and on certain vehicles it may include removal of the transmission. Light duty suspension and brake systems would be replaced with heavy duty factory components, when required, to accommodate the added weight of the battery pack. In addition, to strengthen the unibody for accommodating the added weight of the battery pack, and to provide attach points for the electric drive, aluminum beams would enclose the exposed uniframe members of the original structure. Our alterations do not include changing the body or frame by making any cuts into these original structures.

Our purpose in this endeavor is to eventually offer these types of vehicles for sale to fleet operators and the general public, while complying with all safety requirements. We are aware of the temporary exemptions from motor vehicle safety standards provided in Part 555 of the Act, but prefer, for resale purposes, to be in compliance of the original standards.

Prior to beginning this exercise, we would like to more clearly understand the provisions of the safety regulations. We understand the type of alterations we plan to conduct on new and used vehicles are covered in Part 567.7 - Requirements for persons who alter certified vehicles. As I stated in the above paragraphs, we do not plan to make any changes to the original unibody structure, only to strengthen it for the additional weight of the battery pack. Therefore, we would only be adding additional weight to the vehicle, but not beyond the original Gross Vehicle Weight Rating (GVWR) or Gross Axle Weight Ratings (GAWR). In addition, the center-of-gravity of the vehicle would possibly be changed depending upon the locations of the added weight. In referring to Part 567.7, we understand our only requirement, because of the change in vehicle weight, is to affix to the vehicle an additional label (as described) stating the modified GVWR, and GVAR.

We are requesting, based upon your interpretation of Part 567.7, if the vehicle, altered as described, would be in compliance of all NHTSA requirements.

If you require additional information regarding this matter, I would be happy to respond. Your attention to this request is appreciated!