ID: 11240-2PJA

Mr. Thomas D. Turner
Manager, Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley, Georgia 31030

Dear Mr. Turner:

This responds to your September 20, 1995, letter asking three questions about school bus requirements in Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus emergency exits and window retention and release.

Your first question is whether, under NHTSA's May 9, 1995, final rule amending FMVSS No. 217, a left side exit door would have to meet the emergency exit location requirements if there were also two exit windows that by themselves satisfy the additional exit requirement of Table 1. The answer is no. Table 1 requires buses with a seating capacity of 46 or larger to have as additional emergency exits "1 left side exit door or two exit windows" (emphasis added). The word "or" indicates that either is sufficient. Therefore, if both a door and two exit windows are provided, the manufacturer could designate either as satisfying the requirements, and the other would not be required to meet the location requirement. Section S5.2.3.2(a)(2)'s location requirement is explicitly limited in scope to only "the first side emergency exit door installed pursuant to Table 1." (emphasis added). Additional exit doors beyond those required would not be considered to be installed pursuant to Table 1.

Standard No. 217 formerly contained a provision requiring that emergency exits installed in addition to what is required for school buses have to meet the requirements for emergency exits from non-school buses. This requirement was dropped from the standard on January 27, 1976 (41 FR 3871). We note, however, that in an emergency, the extra emergency exit could be the exit

of choice by some occupants. To avoid confusion, the force and motion needed to open the exit should be consistent with the other emergency exits.

Further, the voluntarily installed side exit doors would still be subject to prohibitions and requirements that apply to side exit doors generally. For example, S5.2.3.2(a)(4) prohibits installing two side exit doors "in whole or in part, within the same post and roof bow panel space." In addition, section S5.2.3.2(a)(1) requires "each" side exit door to be hinged on its forward side (not merely those doors installed pursuant to Table 1).

If windows are used to comply with the additional emergency exit requirements of Table 1, they should be located in the same place as the emergency exit door would have been, "as near as practical to the mid-point of the passenger compartment." See the attached August 4, 1995, interpretation letter that NHTSA sent to Thomas Built Buses on this subject.

Your second question concerns the language in S5.2.3.2(c) of the same final rule stating that "[s]chool buses shall not be equipped with horizontally-sliding emergency exit windows." Blue Bird sells some buses with windows that have sections that slide horizontally to provide ventilation, but also push out to create an emergency exit opening. You were concerned that the literal language of the final rule would prohibit these windows because they are emergency exit windows and they slide horizontally. Instead, your understanding is that the language "horizontally-sliding emergency exit windows" was intended to mean "windows that create the exit opening by sliding horizontally."

Your understanding is correct, because NHTSA does not prohibit horizontally-sliding windows generally. There are no safety concerns about horizontally-sliding emergency exit windows that do not apply to other windows in the school bus, unless the window is opened horizontally to its wider, emergency exit-size opening.

Your third question concerns the requirement in the May 9, 1995, final rule that "[i]n the case of windows with one release mechanism, the mechanism shall require two force applications to release the exit." This language first appeared in a November 2, 1992, final rule. NHTSA acknowledged in a June 13, 1994, interpretation letter that the language was incorrect and should have read "[i]n the case of windows with one release mechanism, the exit shall require two force applications to open." (emphasis added). The June 13 interpretation stated NHTSA's intention not to enforce the rule so long as the exit requires two force applications to open, and to issue a correction notice in the future. The language was unfortunately repeated in the May 9, 1995, final rule, but the June 13 interpretation still reflects the agency's position.

I hope this information is helpful. If you have any further questions, feel free to contact Paul Atelsek of my staff at 202-366-5260.

Sincerely,

Samuel J. Dubbin Chief Counsel ref:217 d:3/20/96

ID: 11241

Mr. Richard P. Cuvala
Trix Mfg. Co. Inc.
500 W. Irving Pk. Rd.
Bensenville, IL 60106

Dear Mr. Cuvala:

This responds to your letter of September 10, 1995, concerning "conference and display vehicles" you have been asked to manufacture for a client. The vehicles used are cargo vans with a gross vehicle weight rating of 9200 pounds. You convert the cargo area of the van to a product display and conference area. Your letter contained an illustration of the vehicle, indicating an L-shaped seating area behind the driver and front passenger seats. Your letter states that this area is not intended for transport of people. You asked whether such a vehicle must comply with "seating and occupant orientation and restraint directives." As explained below, the seats in such a vehicle would have to comply with federal standards on seats and seat belts if the modification is done prior to the first retail sale of the vehicle.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal Motor Vehicle Safety Standards that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. NHTSA does not approve or certify any vehicles or items of equipment. Instead, each manufacturer is required to certify that its motor vehicles comply with all applicable Federal safety standards prior to their sale or import. NHTSA's certification regulations are set forth in 49 CFR Part 567.

Conversion Prior to Sale

Your letter does not state whether the conversion of the cargo area of these vehicles is done before or after the first retail sale of the vehicles. Prior to the first retail sale of a vehicle, the vehicle is considered to be "new." If the conversion is done prior to the first retail sale, your company would be considered an "alterer" under our regulations. A person who alters a previously certified new vehicle also must certify that the altered vehicle complies with all applicable standards (49 CFR '567.7).

The seats in a new vehicle must comply with federal regulations if they are "designated seating positions." A "designated seating position" is defined in 49 CFR 571.3 as:

any plan view location capable of accommodating a person at least as large as a 5th percentile adult female, if the overall seat configuration and design is such that the position is likely to be used as a seating position while the vehicle is in motion.

While you indicate that the vehicles are not intended to transport people except in the front seats, the design of the seating area is similar to other vehicle seats. Therefore, it appears from their design that these seats are likely to be used and are therefore designated seating positions.

NHTSA has exercised its authority to establish five safety standards which could be relevant to seats in these vehicles: Standard No. 207, Seating Systems (49 CFR 571.207), Standard No. 208, Occupant Crash Protection (49 CFR 571.208), Standard No. 209, Seat Belt Assemblies (49 CFR 571.209), Standard No. 210, Seat Belt Assembly Anchorages (49 CFR 571.210), and Standard No. 302, Flammability of Interior Materials (49 CFR 571.302).

Standards Nos. 207, 208, 210, and 302 apply, with certain limited exceptions not relevant to your conversion, to vehicles and not directly to items of equipment. Standard No. 207 establishes requirements for seats, their attachment assemblies, and their installation to minimize the possibility of their failure in a crash. Standard No. 207 does not require a specific orientation for seats. However, some of the requirements are different for side- and rear-facing seats like those illustrated in your attachment.

Standard No. 208 specifies seat belt requirements for seating positions in vehicles. For the seats in the rear of your vehicles, Standard No. 208 would require lap belts at each designated seating position. Standard No. 210 specifies performance requirements for seat belt anchorages. Standard No. 302 specifies burn resistance requirements for materials used in the interior of motor vehicles. Standard No. 302 would affect not only the seats, but also installation of other materials in these vehicles.

Standard No. 209 applies to seat belt assemblies as separate items of motor vehicle equipment, regardless of whether the belts are installed as original equipment in a motor vehicle or sold as replacements. Thus, the manufacturer is required to certify that the seat belts comply with Standard No. 209. If you do not manufacture the seat belts yourself, you should install only belts certified by their manufacturer. This is true regardless of whether the conversion occurs before or after the first sale of the vehicle.

Conversion After Sale

If the conversion is done on a used motor vehicle, you do not have to certify that the vehicle complies with Standards Nos. 207, 208, 210, and 302. However, 49 USC '30122 provides, in pertinent part:

A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative, any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard. . . .

Thus, you could not convert these vehicles if the conversion affected a device or element of design, installed prior to sale, so as to cause the vehicles to no longer comply with any of the safety standards.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:207#208#209#210#302 d:12/8/95

ID: 11244

Mr. Ben Ray
Route 2, Box 229-E
Savannah, TN 38372

Dear Mr. Ray:

This responds to your letter asking about Federal requirements for automatic brake adjusters on log trailers. According to your letter, you manufacture log trailers, using used axles that already have what you call "regular" (i.e., manual) brake adjusters on them. In an October 13, 1995 telephone conversation with Mr. Marvin Shaw of my staff, you further stated that the wheels, brakes, and suspension are typically used, but that occasionally you use new brake systems. You also clarified that these trailers are used on the public roads as well as in the woods for transporting logs to the mills. You asked whether it is permissible to use manual brake adjusters instead of automatic adjusters. The answer depends on whether your log trailers are equipped with new or used components and the trailer continues to use the Vehicle Identification Number (VIN) and to be owned by the user of the reassembled vehicle.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) issues safety standards for new motor vehicles and new motor vehicle equipment. The agency does not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to certify that their vehicles or equipment meet all applicable standards. One such standard is Standard No. 121, Air brake system, which requires new trailers to be equipped with automatic brake adjusters. The following represents our opinion based on the facts provided in your letter.

NHTSA's regulations specifically address the question of when trailers produced by combining new components and used materials are considered to be new trailers. Section 49 CFR 571.7(f) states that when new and used components are used in trailer manufacture, the trailer will be considered "newly manufactured" unless each of the following three conditions is true with respect to the trailer. First, the trailer running gear assembly, which includes the axle(s), wheels, braking and suspension, is not new and was taken from an existing trailer. Second, the existing trailer's identity is continued in the reassembled vehicle with respect to the VIN. Third, the existing trailer is owned or leased by the user of the reassembled vehicle.

In other words, a log trailer will generally be considered newly manufactured, unless all these conditions are met. If a trailer is considered newly manufactured, then it must comply with the

current requirements applicable to trailers. Among other things, this means that the trailer must be equipped with automatic adjusters. If a trailer meets these three conditions, then it is considered not newly manufactured and may be equipped with manual adjusters.

I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:121# 571 d:11/9/95

ID: 11245

Mr. Yoshiaki Matsui
Manager
Automotive Equipment
Legal & Homologation Section
Stanley Electric Co., Ltd.
2-9 13, Nakaameguro, Meguro-ku
Tokyo 153, Japan

Re: Accessory Lamp with LEDs

Dear Mr. Matsui:

This responds to your letter of September 18, 1995, describing a combination tail, stop, and rear turn signal lamp which incorporates incandescent bulbs to perform assigned functions, and which contains light- emitting diodes (LEDs) in a compartment along the outboard side.

With respect to red LEDs adjacent to the tail and stop lamp, you state that the lamp is designed to conform to Standard No. 108 using the incandescent bulbs only, and that you regard the LEDs as an "accessory" acceptable to NHTSA (Your Question 1).

We agree. Because the LEDs are not necessary to conformance with Standard No. 108, they are considered supplemental lighting equipment. Such equipment is permitted by paragraph S5.1.3 of Standard No. 108 if it does not impair the effectiveness of lighting equipment required by Standard No. 108. You state that when the taillamp and LEDs are lit simultaneously, the total intensity does not exceed the maximum intensity specified for a one-section taillamp. It would therefore appear that the presence of the LEDs does not impair the effectiveness of the taillamp (or the stop lamp, which will have a higher intensity).

The red LEDs will provide a red color through the amber lens that covers the turn signal lamp, and will remain on when the turn signal is activated (Your Question 2). This design also appears permissible. We have never considered contiguous rear steady-burning red and flashing amber lamps to be prohibited by Standard No. 108 (the basic design of your lamp), and we do not believe that the supplemental red LEDs will impair the effectiveness of the amber turn signal lamp.

If you have any further questions, you may refer them to Taylor Vinson of this Office (phone: 202-366-5263).

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:108 d:11/9/95

ID: 11246-2DRN

Mr. Mike Love
Manager, Compliance
Porsche Cars North America, Inc.
100 West Liberty Street
P. O. Box 30911
Reno, NV 89520-3911

Dear Mr. Love:

This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect. You asked how the requirement in S3.1.4 concerning display of shift lever positions would apply to the Porsche Tiptronic transmission in the event of a serious fault in the transmission. As explained below, the vehicle would not need to meet S3.1.4 when it detects a serious fault in the transmission.

In your letter and in a telephone conversation with Dorothy Nakama of my staff, you explained that the Tiptronic transmission has a default "limp-home" mode which is enabled whenever a serious fault is detected in the transmission control unit. In this mode, the vehicle automatically goes into fourth gear drive. This allows the driver to get the car to a dealership where the fault can be repaired. If the driver attempts to move the shift lever, the vehicle's transmission would not go out of fourth gear. However, the driver would be able to put the vehicle into "park." You stated that Porsche plans to indicate to the driver that the transmission has entered the limp- home mode by flashing alternately the gear position indicator and the gear number indicator.

S3.1.4.1 of Standard No. 102 states that:

[I]f the transmission shift lever sequence includes a park position, identification of shift lever positions, ... shall be displayed in view of the driver whenever any of the following conditions exist:

(a) The ignition is in a position where the transmission can be shifted.

(b) The transmission is not in park.

The question you raise is similar to one we addressed in a July 29, 1993 interpretation to Mazda (copy enclosed). In both situations, NHTSA is asked to address whether, in an abnormal functioning of the vehicle, the vehicle must continue to meet Standard No. 102. In the letter to Mazda, we stated that Standard No. 102 presumes a functioning vehicle with a functioning gear shift lever sequence. One of the purposes of Standard No. 102 is to reduce the likelihood of shifting errors. In the letter to Mazda, NHTSA went on to state:

In the event of a power failure in a vehicle incorporating electronic transmission gear shift sequence displays, the vehicle would not be capable of being driven, or of having its gears shifted. Therefore, since the standard did not contemplate driving or shifting gears in the event of a power failure, the standard was not intended to regulate the transmission shift display in the event of an electrical or other power failure, when the vehicle is taken out of the "park" position in order to be towed.

Similarly, in the event of a fault in Porsche's Tiptronic transmission, as you indicated to Ms. Nakama, the vehicle would not be capable of being driven above the fourth gear, or of having its gears shifted. Since Standard No. 102 presumes a normally functioning vehicle, in the event of a fault in the Tiptronic transmission, the vehicle need not meet Standard No. 102's requirement that the "identification of shift lever positions, including the positions in relation to each other and the position selected, shall be in view of the driver."

I hope this information is helpful. If you need any further information, please contact Dorothy Nakama of my staff at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosure

ref:102 d:3/13/96

ID: 11247

Dorothy Jean Arnold, M.D.
15 Fairview Knoll N.E.
Iowa City, Iowa 52240-9147

Dear Dr. Arnold:

This responds to your letter asking whether the air bags in your car can be disconnected. You explained that you are physically impaired by the effects of osteomyelitis, a disease of the bones; cannot use a seatbelt with comfort; and were Agranted dispensation from such usage several years ago.@ In a telephone conversation with Richard Reed of this agency, you indicated that you are 74 years old, 5 feet, three inches tall, and must sit close to the steering wheel because of your medical condition.

As explained below, our answer is that NHTSA will not institute enforcement proceedings against a repair business that disconnects an air bag on your vehicle to accommodate your condition.

Standard No. 208, Occupant Crash Protection, requires that cars be equipped with automatic crash protection at the front outboard seating positions. The air bags in your car were installed as one means of complying with that requirement. The removal or deactivation of one of those air bags by a vehicle dealer is governed by a provision of Federal law, 49 U.S.C. '30122. The section provides that:

A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard.

However, in limited situations in which a vehicle must be modified to accommodate the needs of a person with a particular disability or a person's special medical needs, NHTSA has in the past stated that it would consider violations of the "make inoperative" prohibition as purely technical ones justified by public need, and that it would not institute enforcement proceedings.

I would like to caution you that both safety belts and air bags are very important items of safety equipment. Safety belts are the primary means of occupant restraint, and work in all types of crashes. NHTSA estimates that in 1994, safety belts saved almost 9,200 lives and prevented more than 211,000 moderate to critical injuries. The combination of wearing safety belts and having an air bag installed at a seating position provides vehicle occupants with maximum safety protection in all types of crashes. Also, air bags are designed to offer some protection even when safety belts are not used. Since 1987, air bags are estimated to have saved 911 lives.

NHTSA strongly encourages vehicle occupants to wear their safety belts, since we are concerned about the much higher safety risk faced by unbelted occupants. We understand, however, that you cannot wear your safety belt for medical reasons, and that you are concerned about a possible safety risk from the air bag in such a situation.

While air bags have an impressive overall performance record and are designed to provide some protection even for unbelted occupants, NHTSA has become aware of situations in which current air bags have undesired side effects. These include situations in which an air bag appears to have contributed to serious injuries and even death to vehicle occupants, in minor-to-moderate severity crashes. Information indicates that an air bag might pose a risk of serious injury to unrestrained small statured and/or older people, in particular. I note that NHTSA has recently issued a request for comments (copy enclosed) concerning the agency=s actions to minimize the adverse side effects of air bags and to invite the public to share information and views with the agency.

Since your disability prevents you from wearing your safety belt, and given your age and size, the disability places you in a situation where there may be a risk of serious injury from the air bag. While this particular risk can be addressed by disconnecting the air bag, there are trade-offs: Disconnecting the air bag subjects you to a higher risk in crashes, especially higher-speed crashes, where the air bag would provide protection. We urge you to carefully weigh the trade-offs in making your decision.

If you decide that the risk to you from the air bag offsets the potentially life-saving benefits of the air bag, and you wish to have your air bag deactivated, we would regard the deactivation a purely technical violation of the "make inoperative" prohibition justified by public need. Accordingly, we would not institute enforcement proceedings against any person listed in section 30122 who deactivated the air bag. I would recommend that the manufacturer of the vehicle and/or air bag be consulted on the safest way to disconnect the air bag. I also note that the air bag should only be disconnected from a position where you would be seated. In addition, I strongly encourage you to ensure that every person in your vehicle who can use his or her safety belt does so.

I want to add a caution. The purpose of the "make inoperative" prohibition is to ensure, to the greatest degree possible, current and subsequent owners and users of your vehicle are not deprived of the maximum protection afforded by the vehicle as newly manufactured. Accordingly, if you were to sell your vehicle later, we urge that the air bag be reactivated for the subsequent driver.

I hope that this letter resolves your problem. If you have any other questions, please contact Edward Glancy of my staff at this address or by phone at (202) 366- 2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosure

Ref:208 d:12/ll/95

ID: 11253pet

Jonathan P. Reynolds, Esq.
Cosco, Inc.
2525 State St.
Columbus, IN 47201

Dear Mr. Reynolds:

This responds to your letter asking us to confirm that we consider your submission, dated August 3, 1995, as a timely petition for reconsideration of a final rule published July 6, 1995 (Docket No. 74-09, Notice 42). You enclosed a copy of a Federal Express document to show that your submission was received by NHTSA within the time period provided for such petitions under 49 CFR '553.35.

The Federal Express document, which shows the signature of an agency employee, supports a finding that your submission was timely filed. NHTSA is processing your submission as a petition for reconsideration of the subject rule.

If you have any further questions about your petition, please contact Ms. Deirdre Fujita of my staff at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:553 d:10/24/95

ID: 11258

Mr. Edward J. Googins
Chief of Police
City of South Portland
30 Anthoine Street
South Portland, ME 04106

Dear Chief Googins:

This responds to your question whether passenger seat belts must be installed on a 1982 school bus with a gross vehicle weight rating (GVWR) of 20,200 pounds. The answer is no; NHTSA's regulations do not call for the belt systems.

In a telephone conversation with Dorothy Nakama of my staff, you stated that the subject of your letter, a 1982 International - Model #S1700 bus with a GVWR of 20,200 pounds, was manufactured as a school bus.

Federal Motor Vehicle Safety Standard No. 222, School bus passenger seating and crash protection, establishes occupant protection requirements for school bus passenger seating and restraining barriers. Standard No. 222 did not in 1982, and does not now, specify that newly manufactured school buses with a GVWR of 20,200 pounds have passenger seat belt assemblies. Thus, under Standard No. 222, your 1982 school bus need not have seat belt assemblies for passengers.

However, please note that the States are free to require seat belts in large school buses used to transport students. Enclosed is a February 14, 1992 letter to Mr. Michael A. Martin of the Maine Bureau of Highway Safety, addressing the relationship between Federal school bus safety standards and state law. Note that on page two, NHTSA explains that a State may require seat belt installation for school buses procured by the State, as long as Federal compartmentalization requirements are not compromised.

I hope this information is helpful. If you need any further information, please contact Dorothy Nakama of my staff at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel ref:222 d:12/8/95

ID: 11275

M. Guy Dorleans
International Regulatory Affairs ManagerValeo
34, rue Saint-AndrJ
93012 Bobigny Cedex
France

Dear M. Dorleans:

This responds to your letter of September 29, 1995, with respect to the use of light-emitting diodes (LEDs) to fulfill the lighting requirements of Standard No. 108.

You have enclosed a design for a lamp incorporating tail, stop, and rear turn signal functions, the illumination for which will be provided by red LEDs. At night, the LEDs will provide sufficient illumination to meet taillamp photometrics, with increased illumination when the brake pedal is applied, "so that the sum of the photometrics of the stoplamp and the tail lamp is fulfilled." When the turn signal is activated, "all the diodes are energized at full intensity during the on-period of the turn signal [and] [t]he sum of the photometrics of the rear turn signal lamp and the tail lamp is then fulfilled . . . ." You ask for "confirmation that this new lighting combination is correct."

We consider this lamp, as you have more fully described it in your letter, to be an acceptable design for meeting the requirements of Standard No. 108.

If you have any questions, you may refer them to Taylor Vinson of this Office (phone: 202-366-5263).

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:108 d:11/9/95

ID: 11281

Mr. B`rje Kukka
Humalistonkatu 5
00250 Helsinki
FINLAND

Dear Mr. Kukka:

This responds to your request for an interpretation whether NHTSA's statutes and regulations would apply to a process you intend to market, in which two horizontal parallel grooves are etched into the lower portion of motor vehicle windshields. The groves apparently facilitate windshield cleaning by scraping water and debris off the windshield wipers as the wipers pass over the grooves. You provided a videotape on the process and a portion of a windshield etched with the grooves.

I am enclosing two interpretation letters, one dated March 1, 1985 and another dated October 28, 1988, both addressed to Mr. Andrew P. Kallman of Lansing, Michigan. Mr. Kallman asked NHTSA's opinion of a process that is very similar to your process. The letters explain how NHTSA's regulations would apply if your process were used on new vehicles or windshields and on windshields of a used vehicle.

Please also note, NHTSA has no authority to "approve" or certify your process. If you understood any previous correspondence from agency personnnel to mean that NHTSA approves of your product, has endorsed it in any manner, or has made commendations about it (e.g., it "can improve a driver's ability to drive safely"), that is incorrect, and we apologize for any confusion.

State laws may affect operations that you conduct in that State. If you decide to do business in a particular State, you should seek legal advice on requirements for conducting your type of business in that State, including requirements the State may have for persons modifying windshields or for vehicles with modified windshields.

I hope the enclosed information is helpful to you. Should you have any questions concerning NHTSA's legal authority, please write to me at this address or contact Dorothy Nakama of my staff at (202) 366-2992. Our FAX number is (202) 366- 3820. I am, under separate cover, returning your videotape and windshield portion.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosures

ref:104#205 d:11/13/95