Interpretation ID: aiam3114
Executive Vice President
Phillips Motor Car Corporation
1301 West Copan Road
Suite 3E
Pompano Beach
CA 33046;
Dear Mr. Mitchell: This is in reply to your letter of September 22, 1979, asking whethe Phillips Motor Car Corporation is a 'manufacturer' or 'alterer' of the Berlina Coupe.; As you have described it, Phillips removes the body from a 198 Corvette, lengthens the frame and install (sic) newly manufactured body parts, retaining the interior safety features of the original vehicle.; It is clear from your description that Phillips alters previousl certified vehicles 'other than by the addition, substitution, or removal of readily attachable components such as mirrors or tires and rim assemblies ...' and is, therefore, subject to the certification requirements of Title 49, Code of Federal Regulations, Section 567.7. I enclose a copy of the regulation for your information and would be pleased to answer such further questions as you may have.; Sincerely, Frank Berndt, Chief Counsel