Interpretation ID: aiam3488
Director
Automotive Emission Control
General Motors Corporation
General Motors Technical Center
Warren
MI 48090;
Dear Mr. Fisher: This responds to your letter of September 17, 1981, requesting NHTSA' confirmation that certain small, utility-type vehicles to be produced by General Motors would be classified as 'light trucks' for fuel economy standards compliance purposes. In your letter you point out that these future vehicles, at least in base form excluding optional rear seats, would have greater cargo-carrying volume than passenger- carrying volume, a criterion for classifying vehicles as light trucks under our regulations.; As you correctly note, SAE Recommended Practice J1100a specifies tha cargo and passenger volumes are to be determined on the basis of a 'base' vehicle, i.e., one without optional equipment. Further, EPA regulations set forth in 40 CFR 600.315-79(c) provide that all dimensions and volumes are to be determined from base vehicles without options, for purposes of grouping vehicles in classes of comparable vehicles. Strictly speaking, however, neither the SAE Practice nor the EPA provision explicitly apply to the determination of cargo-carrying volume for utility vehicles under our vehicle classification regulations in 49 CFR Part 523. Those regulations are silent on the issue of the inclusion of options for determining interior volume.; Nevertheless, to achieve uniform treatment for passenger automobile and light trucks and to reduce the complexity of accounting for different variations of vehicles sold based on optional equipment, we interpret Part 523 to require that vehicle classification be determined on the basis of the vehicle without optional equipment installed. Therefore, we agree that two-wheel drive utility vehicles which are truck derivatives and which, in base form, have greater cargo-carrying volume than passenger-carrying volume should be classified as light trucks for fuel economy purposes.; Sincerely, Frank Berndt, Chief Counsel